Platform & Services Privacy Policy

Last Updated October 1st, 2023

Our Privacy Commitment

This Privacy Policy (“Policy”) explains how Givsly PBC, ("Givsly"), and its subsidiaries and affiliated companies (collectively, “Givsly”, “we”, “our”, or “us”) collect, use, and disclose personal information through the services we provide, including Good Advertising, Good Events, Good Marketing and Donation Offers (found at https://offer.givsly.com/client/uniqueID or at https://do.givsly.com/client/uniqueID). (collectively the “Services”).

Givsly operates an online platform which provides tools for purpose-led advertising and marketing, simultaneously creating opportunities to give back and donate to various nonprofit organizations who have joined the platform.

Good Advertising allows for Givsly Clients and brands to discover nonprofits whom they would like to support in their messaging, request collaboration from these nonprofits in their campaigns and to create & download a measurement pixel to be placed in a Givsly Client’s advertising creative. The measurement pixels count impressions of users who have seen or engaged with an ad, potentially picked a specific nonprofit and enable brands to make a donation to a selected nonprofit based on the number of ad views (CPM) or other agreed upon engagement. (“Good Advertising”).

Good Marketing allows Givsly Clients to tie purpose driven messaging to their marketing efforts Givsly Clients using Good Marketing can create and distribute digital Donation Offers (in the form of Donation Offer Links or QR codes) in connection with different types of marketing activities at the end of which Givsly Clients make donations to nonprofits e.g. in lieu of handing out physical gifts or swag or as a thank you to their own customers for registering to a seminar or for visiting an event (“Good Marketing”).

Good Events include virtual or in-person events that Givsly helps organize on behalf of Givsly Clients for Givsly Client’s employees, customers or other interest groups and such events typically include partnering with and a donation by the Givsly Client to one or multiple nonprofit organizations.

We ask that you take the time to read this Policy carefully.

Table of Contents #

1. Changes to this Privacy Policy
2. What this Privacy Policy Covers
3. Information Collected, Used, and Disclosed
4. Your Privacy Choices
5. Children
6. Safeguarding & Retention of Your Personal Information
7. For Users in the United Kingdom (UK), European Economic Area (EEA), or the European Union (EU)
8. California Residents
9. Contact Us

Changes to this Privacy Policy #

We encourage you to review this Policy to make sure that you understand our information collection, use and disclosure practices when we provide our Services. We may change the provisions of this Policy at any time and will indicate when changes have been made by revising the date at the top of this Policy. If we make material changes to this Policy, we will provide you with additional notice of such changes by updating our Site and/or by sending you a notification via email, and/or get your permission to use your data accordingly where applicable.

What this Privacy Policy Covers #

This Policy is effective as of the date first posted above and applies only to information collected by Givsly through our Services about Givsly’s clients (“Givsly Clients”). Please note, when Givsly processes personal information in providing its Services, Givsly acts as a “data processor” or “service provider” depending on the jurisdiction and applicable data protection law.

For clarity, this Policy does not apply to any other mobile apps, or any apps or websites maintained by other companies, organizations, or third parties to which we may link, or that may use the Givsly Good Advertising pixel. Your use of any third-party app and/or website is subject to such third party’s applicable privacy policies and terms of use, and we encourage you to read the third parties’ privacy policies and terms of use before submitting personal or other information or using that app and/or website. This policy applies only to Services provided by Givsly accessible through Givsly.com (for example accessing the Givsly user interface), company.givsly.com and the Donation Offer landing pages under do.givsly.com/client/uniqueofferID or offer.givsly.com/client/uniqueofferID.

This policy does not describe the data collection and use practices from Givsly.com, and company.givsly.com. which can be found in our web privacy polity here.

Information Collected, Used, and Disclosed #

Personal Information

We may collect or receive certain personal information from GIvsly Clients to the extent reasonably necessary to carry out our Services.

At times, Givsly Clients will supply us with personal information about their employees, or about the contacts to whom they want to send or otherwise provide Donation Offers or pre-registration lists of their event participants, so we may execute Donation Offers or our Services on behalf of Givsly Clients. To provide access or to enable Givsly Services, Givsly may collect:

• Name
• Company email address
• Company name and job title
• Profile photo (if user wishes to provide it)
• General office location (including country, city, state or zip/postal code)
• Business phone numbers (if user wishes to provide it)
• Industry in which they work
• Non-profit preferences
• IP address
• Givsly may use a measurement pixel in the provision of its Services to count impressions of users who have seen or engaged with an ad, to enable brands to donate to a selected nonprofit based on the number of views. These measurement pixels may in addition to the selected nonprofit choice provide Givsly with information about the country, state or zip code where the nonprofit choice was made.

Givsly may also receive personal information from Givsly Clients to help enable the processing and execution of Donation Offers. In addition to the information listed above, Givsly Client Donation Offer respondents may optionally provide to Givsly with a:

• preferred method of contact
• preferred method of transport to an event to analyze the event’s carbon footprint, and
• the name of a school or university for recruitment related events.

How do we use personal information?

We will use your personal information collected from our website and the use of our Services in the following ways:

• to facilitate donations to nonprofit organizations, and notifications of the donation to our clients and Donation Offer creators, through our Donation Offers feature;
• to understand what nonprofits end users interact with through our Services,
• to better understand marketing efforts using the Good Advertising pixel;
• Givsly may use Personal Information to contact you concerning use of Givsly Platforms, to administer compliance policies and procedures;
• and to comply with applicable laws

When Givsly’s Client creates a Donation Offer, the user receiving the Donation Offer Link receives it directly from the Givsly Client company who created Donation Offer . The Givsly Client sends the Donation Offer through their company email outreach distribution, newsletter or provides such opportunity through another medium such as a QR code or a social network posting as an example. The Donation Offer respondent’s information will be provided back to the Givsly Client who created the Donation Offer and initiated outreach. Companies who receive notice of a Donation Offer being responded to may use that user’s information in accordance with their own privacy policy. Givsly will only use the user’s information in relation to a Donation Offer response to facilitate the Service, such as for reporting or facilitating the payment of the donation for example.

Givsly may also collect and store statistical, aggregate or anonymous information about a user’s interaction with the Service. We may use this information we collect about our customers, traffic patterns, nonprofit preferences, and related information to better design our Services and to share with reputable third-party vendors. Please note, aggregate and anonymous information is not personal information and cannot directly or indirectly identify an individual.

Disclosure of Personal Information to Third Parties

We may disclose personal information to third parties where required for processing. For example, for processing credit card payments, or to carry out our Services. Givsly partners with other companies (such as Stripe and GiftUp) for payment processing, and the payment information submitted is collected and used by them in accordance with their privacy policies (Stripe Privacy Policy, GiftUp Privacy Policy, ShareTribe Privacy Policy).Givsly doesn’t store payment information apart from the last four digits of a credit card or bank account (as applicable), expiration date, and country, which we require for tax, government regulatory, and security purposes; A Givsly Client making the donation payment may elect to save their payment details. Those details are stored by our service provider, Stripe. Please visit Stripe for more information about their data processing practices.

• https://stripe.com/privacy
• https://stripe.com/privacy-center/legal#faq_6
• GiftUp Privacy Policy
• ShareTribe Privacy Policy

We may disclose personal information to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud.

Your Privacy Choices #

Givsly does not process personal information it receives for its own purposes or use cookies in the provision of its Services.

If you have a question about how personal information is processed please contact us at privacy@givsly.com.

Access, Correction, Deletion and Opt Out

Depending on where you reside and other legal limitations, you may have the right to (1) request to know more about and access the categories and specific pieces of personal information we collect, use, and disclose, (2) request deletion or restriction of your personal information, (3) request correction of inaccurate personal information, (4)opt out of certain processing activities, such as selling, sharing, or targeted advertising,  and (5) obtain your User Information in a portable format.

If you would like to exercise any of these rights, please see our email us at privacy@givsly.com and we will forward your request to the Givsly Client that provided your information to us.

You may also opt out of receiving marketing communications from Givsly by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send to you.

Please note, Givsly Clients using the Givsly Good Advertising pixel, may, on their own, make inferences about users who interact with ads where the Good Advertising pixel is present. To note, Givsly is not making these inferences or collecting any data in relation to these inferences.

Children #

Our Services are not intended for or directed to children. Different jurisdictions set different thresholds for the age of a child. Givsly does not knowingly collect or store any personal information about children under the age of 13 or 16 respective of jurisdiction. If you feel we may have unknowingly collected information about a child, please contact us at privacy@givsly.com so that we can delete this data.

6. Safeguarding & Retention of Your Personal Information #

We take appropriate technical and organizational measures to ensure that personal information disclosed to us is kept secure, accurate and up to date. Givsly’s hosting environments and security measures are continuously reviewed and assessed. We process and store your information in the European Union. We may transfer personal information to countries outside of the European Union, including the United States. We will, where the country to which personal information is transferred has not been found to provide an adequate level of protection, put in place appropriate safeguards to ensure the information is protected.

Givsly retains your information for business purposes, and for as long as is reasonably necessary to provide access to the Services. Givsly will also retain personal information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

For Users in the United Kingdom (UK), European Economic Area (EEA), or the European Union (EU) #

For European Union users, below you will find information regarding our processing of your personal information. When we collect personal information (or personal data in some jurisdictions) through our Services, we act as a “data processor”.

YOUR INFORMATION RIGHTS

If you would like to review, update, or have us delete personal information please contact the company who sent you the Donation Offer directly.

You can exercise the rights outlined below at any time by sending an email to privacy@givsly.com or submitting a request through the “Contact Us” form on our Sites. Givsly will forward your request to the company that provided your information to Givsly or under whose Donation Offer your personal data has been requested.

You have right to:

• be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Therefore, we’re providing you with the information in this Notice
• access and rectification. You have the right to access, correct or update your personal data at any time.
• data portability. The personal data you have provided us with is portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
• be forgotten. Under certain circumstances, you have right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. law to retain it, we will do what we can to delete, destroy or permanently de-identify it.
• restrict processing. Under certain circumstances, you have the right to restrict the processing of your personal data.
• object. Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e., receiving emails from us notifying you or being contacted with varying potential opportunities).
• lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with any local Supervisory Authority about how we process your personal data.
• withdraw consent. If you have given your consent to anything we do with your personal data (i.e., we rely on consent as a legal basis for processing your personal data), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).
• And rights related to automated decision-making. You have the right not to be subject to a decision which is based solely on automated processing and which produces legal or other significant effects on you.

Further information and advice about your rights can be obtained from the data protection or supervisory authority in your country.

California Residents #

Givsly is a service provider as defined by the California Consumer Privacy Act as amended (CCPA), it does not sell or share your personal information processed when providing its Services as these terms are defined under the CCPA.

Contact Us #

If you wish to contact us or if you have any queries about how we process personal information, please contact us at privacy@givsly.com.