At Giving Compass Network (“GivingCompass”, “we”, and “our”) , our fundamental philosophy is “members first.” That value powers all of the decisions we make, including how we gather and respect your personal information.

We’ve crafted the policy below (this “Policy”) to be as clear and straightforward as possible. Our aim is for you—our members—to always feel informed and empowered with respect to your privacy on GivingCompass.

Introduction

We are an online portal designed to enable impact-driven philanthropy, aggregating the best published and original content related, including: how to give, with whom to partner, where to meet, and where to give to maximize your impact.

Our mission is to drive more resources to more impact on the ground for communities and causes. Our services are designed to enable our members to discover and author content, meet, exchange ideas, learn about issues, find opportunities to contribute, and make decisions in a network of trusted relationships (the “Services”).

We use the term “Content” to mean: articles, events, gatherings, groups, networking, members, lectures, books, interactive tools, resources, and so on, in any electronic or printed form: video, podcast, audio, blog, animation, formula, algorithm and any future format known or unknown.

Our registered users (“Members”) share their personal and professional identities, engage with other members or visitors, exchange knowledge and personal and professional insights, post and view relevant content, and find philanthropic opportunities. Content on some of our services is also visible to unregistered viewers (“Visitors”). We believe that our services allow our Members to effectively share their full philanthropic potential. The cornerstone of our effort is to focus on our Members first.

As used in this Policy, the term “personal information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, or credit card number), or information about that individual that is directly linked to personally identifiable information. Personal information does not include “aggregate” information, which is data we collect about the use of the Services or about a group or category of services or users, from which individual identities or other personal information has been removed. This Policy in no way restricts or limits our collection and use of aggregate information.

We may share your information with your consent or as required by law, and we will always let you know when we make significant changes to this Policy.

Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:
We protect your personal information and will only provide it to third parties: (1) with your consent; (2) where it is necessary to carry out your instructions; (3) as reasonably necessary in order to provide our features and functionality to you; (4) when we reasonably believe it is required by law, subpoena or other legal process; or (5) as necessary to enforce our User Agreement or protect the rights, property, or safety of GivingCompass, our Members and Visitors, and the public.

We have implemented appropriate security safeguards designed to protect your information in accordance with industry standards.

This Policy applies to givingcompass.org (the “Site”) and other products and services (collectively the “Services”). We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by posting the revised policy to the Site. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. Changes will become effective as of the “updated” date listed at the top of this Policy. We encourage you to review this Policy from time to time to make sure that you understand how any personal information you provide will be used. Your continued use of the Services following the posting of changes to this Policy will indicate your acceptance of those changes.

1. What information we collect

1.1. Data Controllers
Our Policy applies to any Member or Visitor. We collect information when you use our Services to offer you a personalized and relevant experience. The personal information provided to or collected by our Services is controlled by GivingCompass, 2157 N Northlake Way #220, Seattle, WA 98103. If you have any concern about providing information to us or having such information displayed on our Services or otherwise used in any manner permitted in this Policy and the User Agreement, you should not become a Member, visit our Site, or otherwise use our Services. If you have already registered, you can close your accounts.

We collect your personal information in the following ways:

1.2. Registration
When you create an account with us, we collect information (including your name, email address, and other contact information). To create an account on GivingCompass, you can authenticate using one of your existing social media and email accounts offered by third parties or you can choose to create a passwordless account with us, where a token is created every time you want to use the system. you must provide us with at least your name, email address and/or mobile number, and agree to our User Agreement and this Policy, which governs how we treat your information. You may provide additional information during the registration flow (for example, your postal code or employer) to help you build your profile and allow more customized services. You understand that, by creating an account, we and others will be able to identify you by your GivingCompass profile. We may also ask for your credit card details if you purchase certain additional services.

We DO NOT store passwords in our servers and instead let you sign in with any provider of your choice as explained above.

1.3. Profile Information
We collect information when you fill out a profile. After you create account, you may choose to provide additional information on your GivingCompass profile.

1.4. Using the GivingCompass Sites and Applications
We collect information when you use (whether as a Member or a Visitor) our Site, applications, our platform technology or other Services. For example, we collect information when you view or click on ads on and off our Services, perform a search, join and participate in groups, participate in polls, view content, and share articles on our Services. If you are logged in on GivingCompass or another Service or one of our cookies on your device identifies you, your usage information and the log data described herein, such as your IP address, will be associated by us with your account. Even if you’re not logged into a Service, we log information about devices used to access our Services, including IP address.

1.5. Cookies
We use cookies and similar technologies to collect information.

We use cookies and similar technologies to help us recognize you across different Services, learn about your interests both on and off our Services, improve your experience, increase security, measure use and effectiveness of our Services, and serve advertising. You can control cookies through your browser settings and other tools. By visiting our Services, you consent to the placement of cookies and beacons in your browser and HTML-based emails in accordance with this Policy.

1.6. Advertising Technologies and Web Beacons
We use advertising technologies and web beacons to collect information. If you do not want us to track your behavior on third-party sites, you can opt out. If you do not opt out, you consent to our use of beacons and other advertising technologies.

We target (and measure the performance of) ads to Members, Visitors and others both on and off of our Services through a variety of ad networks and ad exchanges, using the following, whether separately or combined:

• Advertising technologies on and off of our Services, like web beacons, pixels, ad tags, cookies, and mobile identifiers as permitted by mobile platforms;
• Member-provided profile and contact information and categories (for example, “charities in California”);
• Information inferred from a Member‘s profile;
• Your use of our Services (for example, your search history, which pages you visit, your clicking on a GivingCompass ad, etc.) and log files generated as described herein;
• Information from 3rd parties (e.g., advertising partners, publishers and data aggregators) which we use in addition to the information from our cookies (and similar technologies), your profile and use of our Services.

We do not share your personal information with any third-party advertisers or ad networks for advertising without your separate permission. Also, advertising partners may associate personal information collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we contractually require such advertisers to obtain your explicit opt-in consent before doing so.

We adhere to self-regulatory principles for interest based advertising. If you wish to not receive targeted ads from most third party companies, you may opt-out. Please note this does not opt you out of being served advertising. You will continue to receive generic ads or targeted ads by companies not listed with these opt-out tools. You can also opt out specifically from our use of cookies and similar technologies to track your behavior on third party sites.

1.7. Log Files, IP Addresses, and Information About Your Computer and Mobile Device
We collect information from the devices and networks that you use to access our Services.

When you visit or leave our Services (whether as a Member or Visitor) by clicking a hyperlink or when you view a third-party site that includes our plugin or cookies (or similar technology), we automatically receive the URL of the site from which you came or the one to which you are directed. Also, advertisers receive the URL of the page that you are on when you click an ad on or through our Services. We also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing GivingCompass using a mobile device), and the name of your ISP or your mobile carrier. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information on our mobile applications and for fraud prevention and security purposes. Most mobile devices allow you to prevent real time location data being sent to us, and of course we will honor your settings.

In the case of our Android apps, you will be provided notice of the types of data (e.g., location) that will be sent to us. If you choose to use our app after this notice, we process this data to enable registration or preview product features for you. If you choose not to become a Member, we will delete this information.

1.8. Other
We are constantly innovating to improve our Services, which means we may create new ways to collect information on the Services.

Our Services are a dynamic, innovative environment, which means we are always seeking to improve the Services we offer you. We often introduce new features, some of which may result in the collection of new information. Furthermore, new partnerships or content arrangements may result in new features, and we may potentially collect new types of information. If we start collecting substantially new types of personal information and materially change how we handle your data, we will modify this Policy and notify you in accordance with the terms in the Introduction.

2. How we use your personal information

2.1. Consent to GivingCompass Processing Information About You
You agree that information you provide on your profile can be seen by others and used by us as described in this Policy and our User Agreement.

The personal information that you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile. By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of our User Agreement and freely accepting and agreeing to our processing of your personal information in ways set out by this Policy. Supplying to us any information deemed “sensitive” by applicable law is entirely voluntary on your part. You can withdraw or modify your consent to our collection and processing of the information you provide at any time, in accordance with the terms of this Policy and the User Agreement, by changing your account settings or your profile on GivingCompass, or by closing your GivingCompass account.

2.2. GivingCompass Communications
We communicate with you using GivingCompass email, text messaging, instant messaging and other ways available to us. We may send you messages relating to the availability of the Services, security, or other service-related issues. You can change your email settings at any time. We communicate with you through email, notices posted on the GivingCompass websites or apps, and other means available through the Services. Examples of these communications include: (1) welcome and engagement communications – informing you about how to best use our Services, new features, updates about other Members you are connected to and their actions, etc.; (2) service communications – these will cover service availability, security, and other issues about the functioning of our Services; (3) promotional communications. These messages will be sent to you based on your profile information and messaging preferences.

2.3. User Communications
With certain communications you send on our Services, the recipient can see your name, email address, and some network information. Many communications that you initiate through our will list your name and primary email address in the header of the message.

2.4. Service Development; Customized Experience
We use the information and content you provide to us to conduct research and development and to customize your experience and try to make it relevant and useful to you.

We use information and content that you and other Members provide to us to conduct research and development for the improvement of our Services in order to provide you and other Members and Visitors with a better, more intuitive experience and drive membership growth and engagement on our Services and to help connect professionals to economic opportunity.

2.5. Sharing Information with Third Parties
Any information you put on your profile and any content you post on GivingCompass may be seen by others.

Other people may find your GivingCompass profile information through search engines, or use in services like Twitter in conjunction with your GivingCompass account.

We do not rent or sell personal information that you have not posted on our Services, except as described in this Policy. We will not disclose personal information that is not published to your profile or generated through engagement with our other services, other than as follows:

• with your consent;
• with third party vendors, consultants, and other service providers who work for us and need access to your information to do that work;
• to (i) comply with laws or to respond to lawful requests and legal process, (ii) to protect the rights and property of Giving Compass, our agents, customers, and others including to enforce our agreements, policies, and terms of use or (ii) in an emergency to protect the personal safety of Giving Compass, its customers, or any person; or
• in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

We support middleware providers that offer archiving solutions to firms subject to legal and regulatory archiving requirements, which, with your permission, facilitate the archiving of your communications and other activity by a third party for compliance purposes. Content distributed through our sharing features and third-party integrations may result in displaying some of your personal information outside of our Services. For example, when you post content to a Group that is open for public discussion, your content, including your name as the contributor, may be displayed in search engine results.

2.7. Polls and Surveys
We conduct our own surveys and polls and may also help third parties do this type of research. Your participation in surveys or polls is up to you. You may also opt out of getting invitations to participate in surveys.

Polls and Surveys may be conducted by us, Members, or third parties. Some third parties may target advertisements to you on the results page based on your answers in the poll. We or third parties may follow up with you via email regarding your participation unless you have opted out of receiving email messages.

2.8. Search
Our Services help you search for philanthropic content, companies, professionals, and charitable organizations.

We use personal information from our Services, including Member profiles to inform and refine our search service.

2.9. Groups
You are responsible for any information you post on our Services, and this content will be accessible to others.

If you participate, share content, or import a blog or other content, you should be aware that any information you choose to disclose using these services can be read, collected, and used by other Members, developers, and other third parties, including advertisers. We are not responsible for the information you choose to submit. Your contributions are typically searchable on our Services and some content may be public and searchable on the Internet.

2.10. Compliance with Legal Process and Other Disclosures
We may disclose your personal information if compelled by law, subpoena, or other legal process, or if necessary to enforce our User Agreement.

It is possible that we may need to disclose personal information, profile information, or information about your activities as a Member or Visitor when required by law, subpoena, or other legal process, whether in the United States, Ireland, or other jurisdictions, or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce the User Agreement, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Service; or (3) exercise or protect the rights, property, or safety of GivingCompass, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. In light of our principles, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but do not commit to challenge every demand.

2.11. Service Providers
We may employ third party companies (such as Google Analytics) and individuals to facilitate our understanding of how users use the Giving Compass Services and further enhance our Services in order to maximize the user experience (examples of companies we employ are in the areas of maintenance, analysis, audit, marketing and development). These third parties have limited access to your information only to perform these tasks on our behalf and are obligated to GivingCompass not to disclose or use it for other purposes.

3. Your Choices & Obligations

3.1. Your Information Choices and Changes

If you wish to ask for access, correction, or deletion of any of your personal information held by us or a change in the way we use your information (for which we reserve the right to charge you a fee, as permitted by applicable law), please contact us at support@givingcompass.org. However, we may decline requests that are unreasonable, prohibited by law, or are not required to be honored by applicable law.

You may opt out of receiving promotional emails from GivingCompass by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.  You may also send requests about your contact preferences, changes to your information including requests to opt-out of sharing your personal information with third parties by emailing support@givingcompass.org.

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.  If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site.

Our third-party analytics and advertising partners may provide you with options to opt-out of certain information collection. To opt out of Google Analytics, you can download the Google Analytics Opt-out Browser Add-on.

There are many ways through which web browser signals and other similar mechanisms (for example, "Do Not Track") can indicate your choice to disable tracking, and, while we and others give you choices described in this Policy , we do not currently honor these mechanisms.

3.2. Data Retention
We keep your information for as long as your account is active or as needed. For example, we may keep certain information even after you close your account if it is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this agreement.

We retain the personal information you provide while your account is in existence or as needed to provide you services. We may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Policy and our User Agreement. We may retain personal information, for a limited period of time, if requested by law enforcement. Our Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but we generally delete or de-personalize closed account data consistent with the terms of this Policy.

4. Important Information

4.1. Minimum Age
You have to meet GivingCompass’s minimum age requirements to create an account.

As described in Section 2.1 of the User Agreement, persons must be of Minimum Age to use GivingCompass.

4.2. Safe Harbor
We comply with the U.S.-E.U. and U.S.-Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland.

4.3. Assignment
If GivingCompass is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

4.4. California’s Shine the Light Law
We don’t share any of your personal information with third parties for direct marketing.

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.

4.5. Security
We take privacy and security seriously and have enabled HTTPS access to our site (turn on HTTPS), in addition to existing SSL access over mobile devices. Also, please know that the Internet is not a secure environment, so be careful and never share your personal information on any piece of content you author or share or in any interaction with other members. We DO NOT store passwords in our servers and instead let you login using several options such as Facebook, Linkedin, Google, Microsoft and other social media credentials.

We have implemented security safeguards designed to protect the personal information that you provide in accordance with industry standards. Access to your data on our Services is password-protected, and data such as credit card information is protected by SSL encryption when it is exchanged between your web browser and the Services. We also offer secure https access to the GivingCompass.org website. To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Members are not encrypted, and we strongly advise you not to communicate any confidential information through these means. Please help keep your account safe by using a strong password.

4.6. Transfers of Your Personal Information

Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We maintain primary data centers in the United States. We take steps designed to ensure that the data we collect under this Statement is processed according to the provisions of this Policy and applicable law wherever the data is located. When we transfer personal information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, we use a variety of legal mechanisms, including contracts, in an effort to help ensure your rights and protections.

4.7 Your European Privacy Rights

We adhere to applicable data protection laws in the European Economic Area, which, if applicable to you, includes the following rights:

• If we are processing personal information based on your consent, you have a right to withdraw consent at any time for future processing;
• You have a right to request access to, rectification, or erasure of your personal information, or to transfer or receive a copy of your personal information in a usable format;
• You have a right to object to the processing of your personal information under certain circumstances; and
• You have a right to lodge a complaint with a data protection authority.

4.8. Our Policy on Gathering Information From And Communicating With Children Online

We recognize the unique privacy concerns regarding children and are committed to protecting children's online privacy. Our services are not geared towards children. Pursuant to the Children’s Online Privacy Protection Act guidelines, we do not intentionally or knowingly collect personal information online from children under the age of 13. If a parent or guardian is made aware that a child under the age of 13 has provided us with personal information, please contact us by e-mail at support@givingcompass.org, and we will take commercially reasonable measures to remove the information about the child from our records.

California Online Privacy Protection Act Notice

A Do Not Track (DNT) standard has not been adopted to this day, and therefore GivingCompass doesn’t use DNT signals.

GivingCompass doesn’t authorize the collection of Personal Identifiable Information (PII) from our members on GivingCompass for third party use through advertising technologies without separate member consent.

To learn more about DNT and GivingCompass’s DNT practices, please read on:

On September 27, 2013, California Governor Jerry Brown signed into law A.B. 370, amending the California Online Privacy Protection Act (CalOPPA) to require website operators like GivingCompass to disclose how GivingCompass responds to DNT Signals; and whether third parties collect personally identifiable information (PII) about users when they visit GivingCompass.

Do Not Track (DNT)

What is DNT?
DNT is the concept that has been promoted by regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

What is a DNT signal?
Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that relies on a technology known as a DNT header that sends a signal to websites visited by the browser user about the user’s DNT preference. You can usually access your browser’s DNT option in your browser’s preferences.

Is there a DNT technology standard?
The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a DNT technology standard. While some progress has been made on this issue, it has been slow, and to date no standard has been adopted. Without an industry standard for DNT, users cannot know how any given company abides by a DNT signal they receive from browser headers. GivingCompass is committed to remaining apprised of the W3C efforts to develop a DNT standard.

How does GivingCompass respond to the signal?
GivingCompass takes privacy and security very seriously, and strives to put our members first in all aspects of our business. With regard to DNT, GivingCompass currently doesn’t respond to DNT signals in browsers because no DNT standard has been adopted, as noted above.

What about JavaScript buttons like Share on GivingCompass?
When members visit websites that contain JavaScript buttons (“plugins”), like GivingCompass’s Share button, we receive plugin impressions that we depersonalize in a short period of time. When members interact with our plugins (for example, sharing articles on GivingCompass), we keep this information to improve their, and others’ GivingCompass experience. See our Policy for details.

Does GivingCompass share members’ personally identifiable information with third parties (like advertisers and ad networks)?
GivingCompass is, inherently, a public place, and there is a lot of PII on GivingCompass that is viewable by any visitor. In other words, third parties can find out about you from the info you share on our services.
In the DNT context, however, GivingCompass doesn’t authorize the collection of PII from GivingCompass members through advertising technologies deployed in ads that may appear on GivingCompass without separate consent.How to Contact Us
If you have questions or comments about this Policy, please contact us online or by physical mail at:

Giving Compass Network
Attn: Privacy Policy Issues
PO Box 458
Union, WA 98592