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Privacy Statement

This Privacy Policy (the “Policy”, or the “Privacy Policy”) describes and governs the information that may be collected, stored, used, transferred, shared and disseminated by Capital for Good USA (a U.S. non-profit organization), its affiliates, its philanthropic or charitable funds (including, without limitation, the “Girls First Fund”), this website (www.girlsfirstfund.org), the Capital for Good USA website (www.capitalforgood.org) and any website under our direct control (collectively, “CFG”, “we,” “us,” or “our”).  Please carefully review this Policy before using our website(s), submitting any information to us, or accessing or using any products, services or information we may provide or make available (collectively, the “Services”).  This Privacy Policy does not apply to your use of any website that is not directly controlled by us or affiliated with us, or any website that may link to our website(s), and we are not responsible for the actions, practices or policies of any such other websites or other parties.  

By using our website(s), or by submitting information to us or obtaining or using our Services, you agree to this Policy as well as the Terms of Use, and you consent to the collection, storage, use, transfer, sharing or dissemination of your information as further detailed in this Policy.  If you do not agree to this Policy or the Terms of Use, do not use our website(s) and do not submit information to us or use our Services.

  1. Information We May Collect

We and our third-party service providers may collect, use, store and transfer your personal information or information about you.  We collect information when you provide information directly to us. We also collect automatically or passively certain information from or about you, such as from your browser or device.  The information we collect may include the following:

  • Identity Information, including your first name, last name, usernames or similar identifiers, titles, gender, date of birth, tax identifiers and/or other government issued identifiers, and photographs.
  • Demographic Information, including postal code or location, age and/or income.
  • Contact Information, including billing addresses, delivery addresses, email addresses, telephone number(s), fax numbers, and social media addresses or identifiers.  
  • Financial Information, including credit card, banking or payment information.  
  • Transaction Information, including details about payments from you, donations by or for you, Services you have ordered or received, and other contract, agreement and transaction information.
  • Technical Information, including internet protocol (IP) addresses, login data and information, browser types, versions and languages, time zone settings and geographic location, browser plug-in types and versions, operating systems and platforms, other information about your computer(s) or device(s), operating system, mobile device, carrier information, the state or country from which you access the website(s) and/or the Services, and unique identifiers (such as numbers or characters associated with your computer, mobile phone, or other device).  
  • Location Information, using a variety of technologies such as GPS, IP addresses, and connected or nearby Wi-Fi networks.
  • Profile Information, including your username and password, login information, applications, registrations, purchases or orders submitted by you, your interests, preferences, feedback and survey responses.
  • Usage Information, including information about how and when you use our website(s) or our Services, such as referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the website(s) or Services, the amount of time spent on particular website pages, the date and time you used the website(s) or Services, the frequency of your use, error logs, and other information.
  • Marketing and Communications Information, including your selections and preferences in receiving marketing, communication or other information from us, as well as third parties, and your communication selections and preferences.  
  • User Content, including text (such as questions, comments and suggestions), pictures, audio, videos or other content (collectively, “User Content”) you submit, provide, or share by participating and posting content in chat rooms, forums, interactive features or by other means, any or all of which may be public.  

We may also collect, use and share Aggregated Information, such as statistical or demographic information.  Aggregated information may be compiled or derived from your personal information, but is not considered personal information since does not directly or indirectly reveal your identity.  

  1. How Information is Collected

We and our third-party service providers may collect information about you through a variety of means, and information from or about you may be collected both directly and indirectly.  

  • Direct.  You may give us information, such as by registering, filling in forms, providing information, corresponding with us by any means, signing up to receive emails, newsletters, publications or other information or Services, participating in surveys, panels or research, participating in our programs, activities, initiatives, conferences, seminars or other events, engaging with social media platforms, accounts, communities, chat rooms and/or other interactive services, submitting an application for funding or other support, providing information to make a donation, contribution or payment, inquiring about or applying for employment, or by providing information by any means or by otherwise participating in any information-related process.  

 

  • Indirect.  Information also is collected about you indirectly (passively), and automatically.  We and our service providers may collect data about your use of the website(s) or our Services, such as  by using Internet server logs, cookies, tracking pixels, web beacons, embedded scripts and other technologies.  We and our service providers may also collect technical information about you if you visit other website(s) that employ our cookies.  Certain of these tracking methods and technologies are briefly described below.
    • Cookies are small data files that a website sends to your device while you are viewing the website.  Cookies are stored on the applicable device and can be used for many purposes, including to monitor use of a website, to customize content specific to you to ensure that you do not see the same advertisement repeatedly, to speed up your searches and purchases and to recognize you when you return to a website and/or store your username, password or other information so that you do not have to repeatedly re-input that information.  You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you disable cookies on your device, some features of the website or content may not function properly.
    • Web beacons are small graphic images or other web programming code (also sometimes referred to as “pixel tags”, “clear GIFs” or by other names) that may be included on our website(s) and in our e-mail messages.  Web beacons are embedded invisibly in web pages and may be invisible to you. Web beacons or similar technologies may be used for a number of purposes, such as to count visitors to our website(s), monitor how users navigate our website(s), count how many e-mails that were sent were actually opened, to count how many particular articles or links were actually viewed, and for other reasons.  
    • Embedded scripts are programming code designed to collect information about your interactions with our website(s), such as the links you click.  The code is temporarily downloaded onto your device from our or our service provider’s web server.
    • Flash LSOs and other technologies are used to, among other things, collect and store information about your use of our website(s).  If you do not want Flash LSOs stored on your computer, you may be able to adjust the settings of your Flash player to block Flash LSO storage.  If you do this, however, the functionality of some Flash applications may be reduced or impeded, including, potentially, flash applications used in connection with our website(s) or our online content.

As new technologies or methods are developed, we may collect additional or other information through other means.

  • Third parties.  We may collect information about you or your organization through third parties, such as by checking publicly available information, or by using other methods.  We may also combine information that we collect from you with information that we obtain from other sources or by other means. We have no control over or responsibility for how any other website or party obtains, uses or discloses personal information it collects about you.  

If you are on another website and you opt-in to receive information from us, the other website may forward your (and/or your organization’s) contact and other information to us.  By registering or logging in through a different website, you may be allowing our website(s) to access your information. Any information that we collect from the other website may depend on the privacy settings you have with that other website.  

  • Analytics and other Specialized Providers.  We may work with certain analytics and other specialized providers (such as network advertisers, ad agencies, and analytics companies) to obtain information regarding traffic on our website(s), to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of our website(s) and the effectiveness of our advertisements. Such specialized providers may set and access their own tracking technologies (including cookies, embedded scripts, and pixel tags) and may otherwise collect or have access to information about you.  They may also transfer certain of your information to other parties where required to do so by law, or where such third parties process analytics information on their behalf, subject to each of their own respective Terms of Use and Privacy Policies. By using our website(s), you consent to the processing of data about you by these specialized providers as described.

 

  • User Content.  We may provide you the means to participate in and post User Content, whether publicly or on a more limited basis, through methods such as chat rooms, forums, interactive features or by other means.  This may also be provided or made available by directly on our website(s) or as part of our Services, or by linking our website(s) to a third party service provider, or by other means. Certain information, such as your username and profile picture, may be publicly displayed on our website(s) along with your User Content.  User Content consisting of uploaded files may contain metadata, which may contain personal information or other information about or relating to you. You may wish to remove metadata from your files before transmitting them. Please be aware that anything you post may be made public, and others who have access to your User Content may use it or share it with third parties.  

We cannot limit, prevent or be responsible for how others may use and/or distribute User Content.  By contributing User Content, you represent and warrant that: (a) you are at least 18 years old; (b) that you own, control or otherwise have the rights to such User Content; and (c) that the User Content you submit does not infringe or violate the rights of any third parties.  In addition, you grant us a non-exclusive, royalty-free, worldwide, perpetual, transferable, irrevocable and fully sublicensable right to use, reproduce, modify, adapt, publish, sell, assign, translate, create derivative works from, distribute and display User Content, in whole or in part, as well as your name and certain other identifying information, including without limitation any social media identifiers, pictures, images, likenesses, posts, statements and other information made available or provided by you, in any form, whether now known or subsequently developed.  

If you choose to voluntarily disclose personal information, that information will be considered public information and the protections of this Privacy Policy will not apply.  If you submit User Content, it may be published online or offline at any time. In addition, we may use your User Content and any excerpt from your User Content in connection with our advertising, marketing, publicity and promotional activities.  

  1. How We Use Your Information

We may use the information we collect from and about you in a number of ways, including the following:

  • For the purposes for which you provided it;
  • To identify, recognize and authenticate you;
  • To initiate or provide the features of our website(s), or our Services;
  • To process and administer any transaction or activity by you with us;
  • To communicate with you about your transactions with us, our Services or our website(s);
  • To invoice you for any transaction or Service;
  • To process any process any grant, payment, contribution, assistance or financial transaction and the associated information;
  • To send you newsletters, publications, mailings and other information, in any form and by any means;
  • To send you information about your relationship or transactions with us, account alerts, or other communications;
  • To contact you with information or surveys that we believe may be of interest to you both regarding our Services and those of third parties;
  • To process and respond to your inquiries or to request your feedback;
  • For internal research and reporting;
  • For editorial reasons;
  • To improve the content and features of our website(s), our Services or to develop new services;
  • To enhance our ability to serve you or tailor content to you;
  • For employment, recruiting and similar purposes;
  • With your consent, to call or send you SMS messages regarding your relationship with us or offers or services that may interest you;
  • For compliance, investigation, fraud prevention and safety reasons, including without limitation the protection of privacy, the property and rights of us or others, and protecting against fraud, and harmful, unethical, illegal or deleterious activity or conduct;
  • To enforce the legal terms that govern your use of the website(s) and any Services;
  • To administer and troubleshoot our website(s) and Services; and
  • For other reasons as described in this Privacy Policy or the Terms of Use.

We may use your information to assess what you may want, need or may be of interest to you, and to then proceed to tailor messages to you, provide certain information or notices to you, or to provide offers or display advertisements to you.  

We may use cookies to display information more effectively and to personalize your experience while using the website(s) or the Services.  We may also gather statistical information about the usage of the website(s) in order to improve the design and functionality, understand how the website(s) are used and to assist us with resolving questions regarding the website(s).  You can set or change your browser to refuse all or some browser cookies, or to alert you when website(s) set or access cookies. However, if you disable or refuse cookies, please note that some parts of the website(s) may become inaccessible or not function properly.

We may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties.  We may also aggregate and/or de-identify information collected through the website(s) or Services. We may use such de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and/or others.  

  1. Disclosing Your Information

We may share non-personally identifiable information, such as aggregated user statistics, in our discretion and without restriction.  We may disclose the information we have collected about you, including personal information, as disclosed at the time you provide your information as described in this Privacy Policy or as otherwise not prohibited.  

We may also disclose your personal information in the following circumstances:

  • We may provide access, share with or otherwise disclose your information to third parties who perform services on our behalf or provide services to us, including without limitation marketing, market research, customer support, data storage, analysis and processing, legal, audit, accounting, tax, consulting and other professional services, other operational and support services (such as for banking, investments, insurance, risk, compliance, etc.), website hosting, information technology and related infrastructure provision, and for other reasons as may be applicable.  You acknowledge and agree that your use of our website(s) or Services may include having your personal information transferred to, from and by, and stored and used by our service providers. Such service providers also may store or use your information outside of the United States, European Union countries or the country(ies) in which you reside or access our website(s) or the Services.
  • If online payment or financial transfer functions are on our website(s) or made available for any Services or donations, we may use third party service providers to process payments, contributions, donations, transfers, inquiries, refunds, complaints and other correspondence and contact with you, and we may share information with those service providers for those purposes and to otherwise facilitate these processes and functions.  
  • You acknowledge, consent, and agree that we may access, preserve, use and disclose your information or information you submit or make available or that we collect, if we are required to do so by law or if believe in good faith believe that such is permitted by this Privacy Policy or if such use or disclosure is, in our opinion, reasonably necessary or appropriate for any of the following reasons:  
    • to comply with a legal process or inquiry, or at the request of any governmental authority;
    • to enforce this Privacy Policy, the Terms of Use or agreements, consents, approvals or other documents, including the investigation of potential violations;
    • to respond to any private or governmental legal process, claim, demand or complaint, including without limitation claims that any content violates the rights of a party;
    • to respond to your requests for customer service;
    • to defend or assert our rights, or the rights of others;
    • to protect the property, safety or interests of us, our employees, affiliates, representatives, agents, service providers, you, other users or the public.  
    • to exchange or provide information to prevent or mitigate fraud, to protect IT and other system security, and for similar purposes; and
    • to manage risks, obtain professional advice, enable rights or protections for us or others, and obtain insurance or other protections, and to enable protective or other measures.  
  • We may share your information or information about you with third parties who we think have a similar mission or purpose to us, or whose activities we believe may be of interest to you, to enable those third parties to reach out to you.  We do not sell your personal information to third parties.
  • We may disclose your information to persons or entities that are affiliated with us, as well as persons or entities who may become affiliated with us or who may enter into contractual or other relations with us or our affiliates.  We may also change the ownership, control or other aspects of our organization or our affiliates, which also may result in a transfer of information about you.

Certain browsers may permit you to specify a Do Not Track (“DNT”) setting or preference.  We do not recognize or respond to browser-initiated DNT settings or signals, in part because there is no consensus or agreement as to what DNT means, any associated rights or obligations, and how to apply and comply with DNT.   

  1. Other Websites, Links and Services

Our website(s) and Services may contain links to third-party websites, applications or other services.  Clicking on those links or accessing those websites, applications or services may allow third parties to obtain, store, process, transfer or share information about you.  Third parties may collect data about you and they may also independently collect information or solicit personal information. We are not responsible for the privacy practices or actions of other parties, providers or websites.   

  1. Your Choices

You can review and update certain user information, and certain personal information, either directly on our website(s) or by emailing us at privacy@capitalforgood.org.

You can unsubscribe from emails from us by clicking the “unsubscribe” link listed in the email.  Where you opt out of receiving communications, your choice will not apply to personal information you provided us in connection with Services or other transactions, and we may continue to send you Service related communications.  We also reserve the right to send you certain communications relating to your account or use of any of our website(s), and such messages may not be affected if you opt-out from email communications. Where we need to collect personal information by law, or under the terms of a contract or agreement with you, we may not be able to perform and we may have to cancel a Service with you.

It is important that your personal information with us is accurate and up to date.  Please keep us informed if your personal information changes during your relationship with us.  You are responsible for maintaining the accuracy of the information you submit to us. If you contact us with changes, we will make good faith efforts to make requested changes as soon as reasonably practicable.  Please note that information may be retained for our or our service providers’ administrative or operational purposes and that certain data and information may be retained in archival or backup systems, or for other reasons.  

  1. Hosting and Transfer of Information

Our computer systems are currently based in the United States, and we and our service providers operate in the United States and may operate in other countries.  You consent to having any information you provide us transferred to and from, and stored and processed in, the United States as well as other countries. The United States and other countries may not provide the same level of protection as the privacy laws of your own country or other location(s).  By using our website(s) or any Services, or by providing us any information, you consent to the receipt, transfer, processing and storage of your information in countries or locations that may not offer privacy protections and rights to same extent as your country or place where our website(s) or the Services are accessed or used by you.

  1. Data Security

We use commercially reasonable administrative, technical and/or physical security measures to help protect against the loss, misuse, alteration, destruction and disclosure of your information.  However, no data receipt, storage or transmission or other system can be guaranteed to provide complete safety security at all times and in all circumstances. Accordingly, we cannot and we do not guarantee that the measures or systems that we or our service providers utilize will prevent any unauthorized attempt to access, obtain, use or disclose your information, and we do not guarantee the security of any information that you have provided or may provide.  We will notify of an actual breach of security involving your information where we are required by law to do so.

We disclaim all liability regarding the security of your personal information and information about you.  Your use of our website(s) or any Services, and any information that you provide, is at your own risk.

  1. Data Retention

We will hold your information for as long as necessary to fulfill the purposes set forth in this Privacy Policy or any other agreements we may have with you, or for as long as we are legally required or not prohibited to do so.  Information may be retained for additional time periods for archival or backup reasons, or for legal, accounting, reporting or other reasons or purposes.

  1. Children’s Privacy

Our website(s) and the Services are intended for adults, and are not intended for children (under the age of 13).  We do not knowingly collect information from children. If you are under the age of 13, please do not use or register on our website(s), or use the Services.  If we become aware that we have collected covered personal information from children under the age of 13, we will take reasonable steps to delete it as soon as reasonably possible.  If you are between the ages of 13 and 18, you should not use our website(s) or Services unless you have consent from your parent or legal guardian.

  1. California Residents

Under certain circumstances residents of the State of California have the right to request certain information regarding the disclosure of “personal information” to third parties for such third parties’ direct marketing purposes.  If you wish to make a request for that purpose, please contact us at the address listed in this Privacy Policy.

  1. Additional Information for EU Residents and Certain Other Covered Individuals

We may use your personal information:  

  • Where we need to perform an obligation pursuant to a contract or agreement with you or request from you, or to take steps to enter into a contract or agreement with you or fulfill a request from you;
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.  Our legitimate interests include, without limitation, those related to conducting and managing our entity, affiliates, operations or businesses, including with regard to customer service, marketing, protecting donors, clients, stakeholders, or other parties, individuals, property or rights, improving or enhancing our operations, and managing record-keeping, reporting or other requirements; and  
  • Where we need to comply with a legal, regulatory or other covered obligation.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.  In addition, we may process your personal data without your knowledge or consent where required or not prohibited by law.

You may have the right to withdraw your consent at any time by contacting us.  The entity to contact, and the entity which may under certain circumstances serve as controller, is Capital for Good USA, 1536 E. Lancaster Avenue, Paoli, PA 19301 USA, or privacy@capitalforgood.org.

Residents of EU countries and certain other countries may have additional or other rights under applicable data protection laws.  For instance, covered individuals may be entitled to:

  • Request access to their own personal data.  This allows you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you.  This allows you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data.  This allows you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with applicable law.  Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it affects your fundamental rights and freedoms.  You may also have the right to object to the processing of your personal data for direct marketing purposes. In certain circumstances, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights.
  • Request restriction of processing of your personal data.  This allows you to ask us to suspend the processing of your personal data:  if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data.  This will not affect the lawfulness of any processing carried out before you withdraw your consent.  In addition, if you withdraw your consent, we may not be able to provide certain information or services to you.

In general, you will not have to pay us a fee to access your personal data.  We may, however, refuse to comply with your request under certain circumstances, such as if it is unfounded or excessive.  We may need specific information from you to help us confirm your identity and ensure your right to access your personal data.  We will respond to all legitimate requests as soon as practically possible.

Residents of EU countries and certain other covered individuals may also have the right to file a complaint with an applicable supervisory authority for data protection issues.  We would, however, very much appreciate the opportunity to discuss and handle your concerns directly with you, and we ask that you please contact us prior to contacting a supervisory authority.

  1. Changes and Updates to the Privacy Policy

We reserve the right, at any time and without notice, to change, update or modify this Privacy Policy.  Updates or changes to this Privacy Policy will be posted on our website(s), and will be effective immediately upon posting.  Updates or changes to this Privacy Policy also may be notified to you through a separate notice on our website(s), or by e-mail or other means.  

  1. Questions or Correspondence

If you have questions about this Privacy Policy or wish to correspond with us in connection with the Privacy Policy, please contact us at privacy@capitalforgood.org, or by writing to us at:  Capital for Good USA, 1536 E. Lancaster Avenue, Paoli, PA 19301 USA.