Effective Date: January 31, 2020
- Contact Us.
If you are located in Australia, at:
Give2Give’s Privacy Officer
35 Buckingham St
For individuals located outside of Australia please contact:
Give To Give’s Privacy Officer
351 East 78th Street
New York, NY 10075
For individuals located in the European Economic Area and United Kingdom, Give to Give LLC is the controller of your information.
- Information Collection.
- Information You Provide.
Generally, Give2Give collects information you provide when you complete donations, register to use any of Give2Give’s services or through your use of Give2Give’s services.
Give2Give only collects or holds your information if it is reasonably necessary and relevant to providing Give2Give’s services. This information may include:
- Contact Information, including your full name, postal address, telephone number, email address, social media addresses and other contact details;
- Content, including the content of messages you send to us and correspondence with us;
- Donation Information, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your donations to us;
- Sensitive Information, including details relating to your medical history and financial information, for scholarship assessment; including date of birth, medical records, pay slips, tax records, bank statements, personal budgets and monthly expenditures.
From time to time, Give2Give may receive information relating to you that we have not requested and which is not otherwise described above (“Unsolicited Information”). If Give2Give does receive Unsolicited Information, we will check whether it is reasonably necessary for us to keep it. If it is, we will treat the Unsolicited Information in the same way as the other information described above. If Give2Give determines that it is not reasonably necessary for us to keep it, we will, as soon as practicable, destroy or de-identify the relevant Unsolicited Information.
In some instances, such as the processing of medical records, we may need to obtain your explicit consent.
- Information Automatically Collected.
In addition, we automatically collect information when you use our service, such as:
- Service Use Information, including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
- Device Information, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
- Location Information, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).
We use various current – and later – developed tracking technologies to automatically collect information when you use the Service, including the following:
- Log Files, which are files that record events that occur in connection with your use of the Service.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
- Information from Other Sources.
We also collect information from other sources, including:
- Social networks when you engage with our content or reference our services on social networks.
- Partners that offer co-branded events or services, or engage in joint marketing activities.
- Publicly-available sources, including data in the public domain.
- Use of Information.
We collect and use information in accordance with the practices described in this Policy, including to:
- Operate and manage Give2Give’s services including building a dossier of your application for scholarship;
- Record any donations you may make to Give2Give;
- Perform services requested by you, such as respond to any comments or questions from you;
- Provide you with information about Give2Give, our related companies’ and business partners’ products and services;
- Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- Prevent and address fraud, breach of policies or terms, and threats or harm.
- Develop and send you direct marketing, including advertisements and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
- Monitor and analyse trends, usage, and activities.
- Conduct promotions, including verifying your eligibility and delivering prizes in connection with your entries.
- Conduct research, including focus groups and surveys.
- Improve the service or other Give2Give websites, apps, marketing efforts, products and services.
- Send you advertising tailored to your interests.
- Fulfill any other purposes at your direction or with your consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
- Sharing Information.
We may disclose your information to the following categories of recipients:
- Related companies, services providers, vendors and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our website), or who otherwise process information for purposes that are described in this Policy or notified to you when we collect your information.
- Law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person. For example, it may be necessary to disclose your information if there is a serious threat to an individual’s health or safety, there is reasonable suspicion of unlawful activity, for the conduct of surveillance and intelligence gathering by an enforcement body, or to assist in locating a missing person.
- Actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of Give2Give, provided that we inform the buyer it must use your information only for the purposes disclosed in this Policy; or
- Any other person or entity with your consent to the disclosure.
Give2Give will not sell, rent or trade information about you to or with third parties without your express permission or as set out in this Policy.
- Analytics and Advertising.
We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may incorporate tracking technologies into our own service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, and Interest-based Advertising, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
- Legal Basis for Processing Information.
If you are providing information from the European Economic Area, our legal basis for collecting and using the information described will depend on the information concerned and the specific context in which we collect it.
However, we will normally collect information from you only (i) where we need the information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect information from you or may otherwise need the information to protect your vital interests or those of another person.
If we ask you to provide information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your information is mandatory or not (as well as of the possible consequences if you do not provide your information).
If we collect and use your information in reliance on our legitimate interests (or those of any third party), this interest will normally be for communicating with you as necessary to provide our services to you and for our legitimate commercial or charitable interests, for instance, when responding to your queries, improving our services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided above.
- Data Protection Rights.
Depending on where you are located and the Give2Give entity you are communicating with, you may have a number of rights concerning your information. You can exercise these rights by placing your request in writing and sending it to us using the contact details provided in the “Contact Us” section above. Please include your contact details so that we can communicate with you about your request.
Your rights may include any of the following:
- The right to access, correct, update or request deletion of your information.
- The right to object to processing of your information, ask us to restrict processing of your information or request portability of your information.
- The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided above.
- The right, if we have collected and process your information with your consent, to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
- Making a Complaint.
If you are not satisfied with how we have handled your information, please contact Give2Give’s Privacy Officer via the details listed above. You can also lodge a complaint with a data protection authority. In Australia this is the Federal Privacy Commissioner (www.privacy.gov.au). A list of data protection authorities in the European Economic Area can be found here.
- Your Rights and Choices.
- Tracking Technology Choices.
- Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
- Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove tracking technologies some parts of the service may not function correctly.
- Analytics and Interest-Based Advertising.
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ .
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.
Our service is intended for a general audience, and is not directed at children under (13) years of age. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at firstname.lastname@example.org. We will remove the data to the extent required by applicable laws.
- Information Security.
Give2Give implements and maintains reasonable administrative, physical, and technical security safeguards to secure information about you from loss, misuse, theft and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
We use a Payment Card Industry Data Security Standard compliant hosted payment service to process payment card transactions. We do not collect or store your payment card details. Your payment card details will only be collected and held securely by our third party payment processor, PayPal.
- International Transfers.
Your information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
For example, we may store your information in a cloud, or other type of networking electronic storage which is based in a jurisdiction outside Australia. If we do this, Give2Give will ensure reasonable steps are taken so that the overseas recipient does not breach the Privacy Act 1988 (Cth), or the Australian Privacy Principles in relation to that information, or adheres to laws substantially similar to Australian privacy laws. Give2Give will also take reasonable steps to prevent unauthorised access and reduce the risk of disclosure to unknown entities.
Specifically, our website servers are located in the United States, our group companies are in the United States and Australia, and our third party service providers and partners operate around the world. This means that when we collect your information we may process it in any of these countries.
- Retention of Information.
We retain information we collect from you where we have an ongoing legitimate need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate need to process your information, we will either delete or anonymise it or, if this is not possible (for example, because your information has been stored in backup archives), then we will securely store your information and isolate it from any further processing until deletion is possible.
- Third Party Websites and Services.