Giving Technologies, Inc. and and its affiliates and subsidiaries, including IsraelToremet Ltd. (collectively, “GivingTech” “we,” “our,” and “us”) provide this Privacy Notice (“Notice”) to explain how we collect, use, and disclose information about you through our platforms and serivces, such as our donation forms and Fundraisers (collectively, the “Services”).

Before you access, use, or submit any information through or in connection with the Services, please carefully review this Notice. By using any part of the Services, you acknowledge that you have read and understood that we may collect, use, and disclose information about you as outlined in this Notice. To the extent allowed by law, the English version of this Notice is binding, and its translations in other languages are for convenience only; in case of discrepancies between the English version of this Notice and its translations, the English version shall prevail.

This Notice does not cover the privacy practices of either (i) organizers of Fundraisers (collectively, “Organizers”), (ii) beneficiaries of fundraisers (collectively, “Beneficiaries”), or (iii) nonprofit organizations that use the GivingTech platform (collectively, “GivingTech Clients”). We are not responsible for the privacy practices of Organizers, Beneficiaries, or GivingTech Clients, and their handling of your information may be subject to their own privacy statements.

INFORMATION WE COLLECT

As further described below, we collect information in multiple ways, including when you provide information directly to us, when we collect information about you from other parties, and when we automatically collect information from your browser or device (e.g., by logging how you interact with our Services).

A. Information That You Provide Directly to Us:

We and our vendors may collect information from you directly in various ways, such as when you:

The information you provide us directly may relate to you or others and may include, without limitation:

Account Registration Information: such as your name, email address and login details, your country, your phone number, and certain other information, including any information you choose to provide us (such as a profile picture). If you use the Services as an organization (e.g., a GivingTech Client or any other registered non-profit), you may also provide us with your organization’s name, your role/title with the organization, identification number, and other information about your organization.

Fundraiser Information: such as a fundraiser title, a fundraiser category, images, videos, description and fundraiser goal(s).

Financial Information: such as payment account details for withdrawals and payment information for donations, and billing information. We use third-party payment processors to process financial information. These payment processors may collect personal data, including via cookies and similar technologies. The personal data they collect include transactional data and identifying information about devices that connect to its services. They use this information to operate and improve the services provided to us, including fraud detection, loss prevention, authentication, and analytics related to the performance of services. They operate both as processors for us and independent controllers for the information they collect directly from our users.

Publicly Available and Non-Publicly Available Communications and Content: such as comments, feedback, thank-you notes or other communications with other users through our Services. Any content, including such comments, feedback, and notes that you choose to post on publicly available campaign pages through our Services, are available to the public by default. Please remember that any information that is disclosed in these areas becomes public information for both us and other users to use and share. Take care not to disclose information about you unless you intend for that data to become public. Please also be considerate and respectful of others while using the community to publish your opinions. We reserve the right but do not have the obligation, to review and monitor publicly-available content, non-publicly available communications between users, and any other content made on or through our Services, and to remove postings or content that may be viewed as inappropriate or offensive to others.

Information about Yourself and Others, Including Sensitive Information: such as information about a fundraiser, including the beneficiary of a fundraiser, fundraiser goals, and other information you choose to provide, which may include information about situations or other circumstances that motivate a fundraising request. If you provide us with information about others, you acknowledge and agree that you have the authority and consent of the relevant other parties for us to access, disclose, and use the relevant data, and that you have notified the other parties and informed them of how their information is collected and used by GivingTech to provide the Services. We reserve the right to identify you as the person who has made the referral in any messages that are sent to them.

Chats and Other Communications with Us: such as for troubleshooting or support services. We may engage vendors to provide certain interactive features on our Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on the Services for customer service purposes. When you participate in the interactive chat, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that we and our vendors on our behalf may, on a real-time basis, collect and process the information obtained through the feature. We would ask that you take care not to send financial information or other sensitive personal data to us through our chat services or other means unless we ask you specifically for that data as part of providing the Services to you. When you provide such information to us directly, you consent to the processing of this data by GivingTech and/or our vendors. We collect the information listed in this section for the purposes described below in the sections “Our Use of Information Collected” and “Our Disclosure of Information Collected About You.”

Biometric Information: We sometimes engage vendors to collect biometric information for identity verification, regulatory compliance, and fraud prevention purposes. We or the vendors we engage may collect a copy of your government-issued ID (i.e., your driver’s license, ID card, or passport) and a scan of the picture on your government-issued ID for identification purposes. Our vendors may, with your consent, employ facial recognition technology to verify your identity and share the results of their analysis with us, if needed.

B. Information That is Passively or Automatically Collected:

I. Device & Usage Information:

When you interact with GivingTech through the Services, we automatically receive and store certain information from devices that you use to access the Services such as your IP address. This information is collected passively by using various technologies and includes the type of Internet browser or mobile device you use, any website from which you have come to the Services, your operating system, and inferred location data through an IP address that identifies the city and state where you logged into the Services. GivingTech either stores such information itself or such information is included in databases owned and maintained by GivingTech, and/or its agents or vendors.

II. Location Information:

When you use the Services to organize a fundraiser, the Services may require that you provide your postcode/zip code, city or town, and state or province of residence.

III. Cookies and Other Electronic Technologies:

Please review our Cookie Policy for information on the types of cookies we or our vendors use on the Services, along with how we use those cookies and other electronic technologies.

If we are unable to collect your information, we may not be able to provide you with the Services or assist you with your questions.

OUR USE OF INFORMATION COLLECTED

GivingTech uses the information collected from the Services in a manner that is consistent with this Notice. We may use the information that you provide (or otherwise permit the Services to access) for the following purposes:

• Provide, operate, and maintain the Services, including to register and maintain your account, facilitate the Know Your Customer (KYC) verification process and to complete transactions;
• Communicate with you for various purposes, including to help you fundraise more, or for administrative purposes (e.g., to provide services and information that you request or to respond to comments and questions) regarding the Services;
• Request your feedback;
• Personalization, marketing, and advertising;
• Analyze, improve, modify, customize, and measure the Services, including to train our artificial intelligence/machine learning models;
• Develop new products and services and other research and development;
• Verify your identity and to detect and prevent fraud or other misuses of the Services;
• Maintain the security of your account and any associated fundraisers;
• Comply with legal obligations, law enforcement requests and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other parties, including to enforce our Terms of Service and any other agreements; and
• Carry out any other purpose for which the information was collected.

We may combine information that we collect from you through any or all of the Services with information that we obtain from other sources. For example, we may compile information from a variety of sources to generate inferences about you, such as inferences about your likely interests in making charitable or other donations and the potential size of such donations, starting peer-to-peer fundraisers, signing up for recurring donations or other similar indicators.

We may also aggregate and/or de-identify information collected through the Services. We may use and disclose de-identified or aggregated data for any purpose, including, without limitation, research and marketing purposes.

OUR DISCLOSURE OF INFORMATION COLLECTED ABOUT YOU

There are certain circumstances in which we disclose information collected about you with certain other parties without further notice to you, as set forth below.

A. Business Transfers:

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, similar event, or steps taken in anticipation of such events (e.g., due diligence in a transaction), user information may be part of the reviewed and transferred assets.

B. Affiliates and Subsidiaries:

We disclose your personal information among the GivingTech entities, including our affiliates and subsidiaries, for purposes consistent with this Notice, such as to provide our Services, including hosting; marketing, and publicizing fundraisers; providing you with customer support; administering funds in connection with fundraisers; preventing fraud and misuse; authenticating donors; sending you communications; improving Services offered by the various GivingTech entities and conducting the other activities described in this Notice.

C. Agents, Consultants, and Vendors:

GivingTech contracts with other companies to help us perform certain business-related functions, and we provide access to or disclose your information with these companies so they can perform services for us. Examples of such functions include marketing, mailing information, data storage, security, identity verification, fraud prevention, payment processing, preventing fraud and misuse, legal services, and database maintenance.

D. Legal Requirements:

We may transfer, disclose to, and preserve your information for courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request (such as a subpoena or court order), (iii) respond to claims asserted against us, (iv) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity or to respond to or address any other activity that may expose us, you or any other of our users or members of the public to imminent harm, legal or regulatory liability, (v) enforce and administer our Terms of Service or other policies, or (vi) protect the rights, property or personal safety of GivingTech, its affiliates, its employees, its users, or members of the public.

E. Organizers, Nonprofit Beneficiaries, and GivingTech Clients:

Organizers. We may disclose your information to Organizers, which may or may not be the same as the Beneficiaries of the fundraiser. For example, if you donate to a fundraiser for an individual, we may disclose your name and donation amount to the Organizer who may in some instances also be the Beneficiary. Likewise, if you donate to a nonprofit through GivingTech, you direct us to disclose your donation, contact information and any other information you provide to the applicable nonprofit.

Nonprofit Beneficiaries. Organizers may create fundraisers designating a nonprofit organization as a Beneficiary. Where a nonprofit organization is designated as the Beneficiary, that nonprofit organization may access certain information about the Campaign Organizer and donor information, including the donor’s name, email address, donation amount, date of transaction, transaction identification number, and name of the campaign. GivingTech contractually requires the nonprofit organization to use such information solely to communicate with you about your donation and for legal and auditing requirements. GivingTech may authorize nonprofit organizations to process your information for other purposes (such as marketing) if you opt-in to that processing.

GivingTech Clients and Their Vendors/Partners. GivingTech may power the donation pages and other activities. If you donate to a nonprofit through a GivingTech-powered webpage, you direct us to disclose your donation and contact information to the applicable nonprofit, and such information shall also be subject to the privacy policies and practices of that GivingTech Client. GivingTech Clients may also direct us to further disclose your personal information to other third parties such as CRM tools or other integration partners used by the relevant GivingTech Client. We may also disclose certain information about you, such as information about your interests and donation preferences, to GivingTech Clients who may use such data for their fundraising and marketing operations.

“Anonymous” Donations Limited to Public Activity Feeds. If you selected not to be named publicly on the public fundraiser pages on the Services, while your donation will be designated as “anonymous” on the public activity feed, your name and other information may still be visible to the GivingTech Client, Organizer, any of their team members and the Beneficiary, and will be otherwise processed in accordance with this Notice.

F. Aggregated Data

We aggregate, anonymize and/or de-identify information collected actively or passively about you so that the information no longer relates to you individually.  We then use that data for various legally permissible purposes, including but not limited to our research on our customer demographics, interests and behavior. We also disclose this information with our affiliates, agents, business partners, research facilities or other third parties.

G. Cookies and Other Electronic Technologies

Information is disclosed as stated in the Cookie Policy.

H. Other Users of Our Services

We provide your information to other users of our Services if you choose to make your information publicly available in a publicly accessible area of the Services, such as in your fundraiser through your donations or in the comments.

ONLINE ANALYTICS AND TAILORED ADVERTISING

Analytics. We may use third-party web analytics services on the Services, such as those of Google Analytics. These vendors use the sort of technology described in the “Information That is Passively or Automatically Collected” section above and in our Cookie Policy to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by such technology will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services. We also may use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for web analytics, you may install the Google Analytics Opt-Out Browser Add-on.

Tailored Advertising. We may allow third-party advertising networks to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our website and other online services and (b) report how our marketing content impressions and interactions with these marketing impressions are related to visits to our online services. We may also allow other unaffiliated parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that may be disclosed to a vendor in hashed, non-human-readable form.

LINKS TO OTHER WEBSITES

The Services can contain links to other web sites not operated or controlled by GivingTech (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that GivingTech  endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their respective privacy policies.

SECURITY

We may hold your information we have collected in paper and/or electronic form. While no organization can guarantee perfect security, GivingTech has implemented and seeks to continuously improve technical and organizational security measures to protect the information provided via the Services from loss, misuse, unauthorized access, disclosure, alteration, or destruction.

RETENTION OF YOUR INFORMATION

We retain your information for as long as we deem necessary for the purpose for which that information was collected and for our legitimate business operations; provided, however, that your information is only retained to the extent permitted or required by applicable laws. When determining the retention period for your information, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the Services we provide to you if we delete some information about you, mandatory retention periods provided by law, and any applicable statute of limitations.

CHANGES TO GivingTech’S PRIVACY NOTICE

GivingTech reserves the right to update or modify this Notice at any time and from time to time. We will notify you of any material updates or changes we make to this Notice. If you disagree with our revisions to the Notice, you can deactivate your account or discontinue the use of our Services. Please review this Notice periodically for any updates or changes to this Notice.

By using the Services after any such update or modification, you acknowledge that you have read and understood the terms of the Notice as updated or modified.