PRIVACY POLICY

Last Updated: May 08, 2019

CrowdChange Inc. ("we", "us", "our" or “CrowdChange”) is committed to protecting your privacy. We need to collect certain personal information in order to facilitate the services provided through our websites, mobile applications and other media content (“Services”) that are owned or controlled by CrowdChange, and this privacy policy ("Privacy Policy") is designed to inform you about our practices relating to the collection, use and disclosure of personal information. Please note that CrowdChange goods and Services are in no way sponsored, endorsed or administered by, or associated with, any social media platform, such as Snapchat Inc.

This Privacy Policy governs CrowdChange’s data practices as they relate to its Services. Please do not use the CrowdChange Services if you do not agree with the provisions of this Privacy Policy.

Your use of the Services is also governed by the CrowdChange Terms of Use. Please do not use the CrowdChange Services if you do not agree with the provisions of this Privacy Policy.

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

5. Security

6. Third Party Links

7. Cookies and Ads

8. Opting Out

9. Your Rights

10. Passwords

11. Changes to this Privacy Policy

12. How We Respond to Do-Not-Track Signals

13. Note About Public Posting Areas

14. International Data Transfers

15. Assignment

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.

Send Pictures

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.

Service Providers

 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.

You can find a list of our service providers here

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.

Legal

 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.

5. SECURITY

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

Our Services may contain links to other sites that CrowdChange does not own or operate. We provide event organizers with the ability to have links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

7. COOKIES AND ADS

We, and third parties we work with, use cookies and other similar technologies, such as web beacons to collect information about your interaction with our servers (such as IP addresses, device type, operating system and average time spent using our platform). We collect and use this information for the purposes of helping us understand how users use our Services and to optimize our platform and service offering. We may also collect cookies (including Adobe or flash cookies) and web beacons.

In particular, we use Google Analytics to measure how you interact with our Services and to improve your user experience. To learn more about Google Analytics privacy practices and opt-out mechanisms, please visit the Google Analytics Security and Privacy Principles page here. Google also provides a complete privacy policy and instructions on opting-out of Google Analytics here.

There are several ways to manage cookies. You can control the use of cookies at the browser level, by instructing your browser to accept cookies, disable cookies or notify you when receiving a new cookie. Please note that if you reject certain cookies, you may still use our Services, but your ability to use some features or areas of our Services may be limited.

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 support@crowdchange.co.

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.

10. PASSWORDS

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.

11. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes to our privacy practices. When our Privacy Policy changes, we will update the “Last Updated” date at the top of this Privacy Policy and post a notice via our Services. For material changes, we will notify you by email or message. We also strongly encourage you to refer to this Privacy Policy for the latest information about our personal information practices.

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 will be used for the uses identified above in accordance with this Privacy Policy; and
• Your personal information may be transferred to the United States and other jurisdictions as indicated above.

15. ASSIGNMENT

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

Please contact our Privacy Officer if you have any questions, comments or complaints about this Privacy Policy, or the manner in which we or our service providers treat your personal information. You may contact our Privacy Officer at support@crowdchange.co.