TABLE OF CONTENTS
1. Collection and Use of Personal Information
2. Legal Bases for Processing
3. Disclosure of Personal Information
4. Collection of Information from Children
6. Third Party Links
7. Cookies and Ads
8. Opting Out
9. Your Rights
12. How We Respond to Do-Not-Track Signals
13. Note About Public Posting Areas
14. International Data Transfers
16. Your California Privacy Rights
17. Contacting Our Privacy Officer
1. COLLECTION AND USE OF PERSONAL INFORMATION
The term "personal information" means information that can be used to identify an individual, such as name, phone number, email address, or mailing address. We collect personal information when you:
Use Our Services as a Client
When you use our Services, you may be asked to provide registration information that identifies you ("Registration Information"). We collect personal information and other information regarding your fundraiser including your name; email address; date of birth; fundraiser name; name of entity for which you are fundraising; fundraiser goals; fundraiser photo; an overview of your fundraiser in the “About” section; fundraising team names; mailing address; phone number; and other information you provide in connection with your fundraiser(s). We use this information to provide our Services and we may use this information, with your consent where required, to send promotional messages about the Services.
Make a Donation
When you make a donation, we may collect your name, phone number, email address, mailing address, and billing information. The third party in charge of the fundraiser may ask additional questions. If you make your donation through our White Label Program, the third party hosting the fundraiser collects the information you provide. We use this information to provide our Services, to send promotional messages about our Services, and to provide reports containing aggregated, non-personal information, to our clients about their fundraisers.
When you upload a picture, it will be publicly available to all viewers of your profile and fundraising page. Also, when you send us a picture or message via email, text message, Instagram or Snapchat, we may take a screenshot of your picture or message for the purposes of providing our Services, which may include sharing your picture on our Instagram.
Contact Customer Service
If you contact us with a question, comment or complaint, you may be asked for information that identifies you (such as your name or email address) along with additional information we need to help us confirm your identity (if necessary), and to promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service and service offerings.
2. LEGAL BASES FOR PROCESSING
We process personal information per applicable law and with transparency and fairness. We rely on the following legal bases:
To send promotional messages about our Services, processing is based on your consent where required (Art. 6(1)(1) GDPR).
To provide our Services to you and process customer inquiries and requests, processing is necessary to establish and fulfill a contract with you (Art. 6(1)(b) GDPR).
3. DISCLOSURE OF PERSONAL INFORMATION
We disclose your personal information in the following instances and to the following parties:
Partners and Affiliates
We may share your personal information with organizations to which you donate, as well as affiliated organizations and other entities working on their behalf. For example, if CrowdChange is the host of a website operated by a third party ("partner") we will share your personal information with this partner. With your consent where required, these partners and affiliates may use your personal information for their direct marketing purposes.
Please note that the organizations to which you donate may download a copy of your personal information for their own databases. You will need to contact the organization directly if you wish to have your personal information removed from their database.
We may transfer (or otherwise make available) your personal information to our affiliates, partners and other third parties who provide services on our behalf. We use service providers to host our servers, send communications on our behalf, and process transactions.
Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own purposes.
Sale of Business
We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of our operations or as part of a corporate reorganization or stock sale or other
change in corporate control.
CrowdChange, our affiliates and related companies and our Canadian, US and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by applicable Canadian, U.S. or other law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims, or as otherwise permitted by law.
4. COLLECTION OF INFORMATION FROM CHILDREN
Our Services are not intended for use by and we do not knowingly collect any personal information from children under the age of 13, or 16 in the European Union (“EU”). If we discover that we have such information in our possession, we will destroy it.
We have implemented administrative, technical and physical safeguards designed to protect personal information in our custody and control against unauthorized access, use, modification and disclosure.
That said, no data transmissions over the Internet can be guaranteed to be 100% secure. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using our Services, providing access to our Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of our Services. We may post a notice through our Services if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
6. THIRD PARTY LINKS
7. COOKIES AND ADS
8. OPTING OUT
You may decline to receive promotional emails, text messages or mail from us at the time of registration or at the time you otherwise provide the information to us. You may also opt-out of receiving promotional emails or text messages by following the instructions in those emails or text messages or by sending an email to email@example.com.
If you opt out, we may still send you transactional messages, such as emails about your account or our ongoing business relationship.
9. YOUR RIGHTS
You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. To request access, updating or correction of inaccuracies in your personal information that we have in our custody or control, you can email or write to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. Additionally, those located in the EU have the right to:
Obtain confirmation as to whether or not their personal information exists and to be informed of its content and source, verify its accuracy and request its completion, update or amendment;
Request the deletion, anonymization or restriction of the processing of their personal information processed in breach of the applicable law;
Object to the processing, in all cases, of their personal information for legitimate reasons;
Receive an electronic copy of their personal information, if they would like such a copy for themselves or to port their personal information to a different provider;
Lodge a complaint with the relevant data protection supervisory authority.
While many of our Services are publicly accessible, access to your account information and some of our Services are accessible only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe that the confidentiality of your password has been compromised or that your password has been misused. In addition, always log out and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email. CROWDCHANGE IS NOT RESPONSIBLE FOR ACTIONS TAKEN REGARDING YOUR ACCOUNT WHILE A USER IS LOGGED IN USING YOUR USER ID AND PASSWORD.
12. HOW WE RESPOND TO DO-NOT-TRACK SIGNALS
We do not support Do Not Track browser settings and do not currently participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.
13. NOTE ABOUT PUBLIC POSTING AREAS
Please note that any information you include in a message you post to any public posting area is available to anyone with Internet access. If you do not want people to know your email address, for example, do not include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN PUBLIC POSTING AREAS.
14. INTERNATIONAL DATA TRANSFERS
If you choose to provide us with information, we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the EU or other regions with laws governing data collection and use that may differ from US law, please note that you are transferring your personal information to the United States and other jurisdictions which may not have the same data protection laws as the EU. We take reasonable steps to ensure that such transfers are undertaken in accordance with applicable data protection and privacy laws. You acknowledge you understand that by providing your personal information:
Your personal information may be transferred to the United States and other jurisdictions as indicated above.
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal and non-personal information collected via the Services.
16. YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact our Privacy Officer as provided below.
17. CONTACTING OUR PRIVACY OFFICER