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Grab the playbook: Five steps to grow your recurring program

 * Solutions
   Direct Appeals
    * Donation Forms Raise more from anywhere on your website with frictionless
      forms.
    * Recurring Giving Power sustainable revenue growth and build a community of
      engaged supporters.
    * Donation Websites Bring your story to life with customizable,
      high-converting donation pages.
    * Crowdfunding Create a unique giving hub to rally supporters for major
      campaigns.
    * Giving Cart  New Expand the potential of each appeal with modern,
      e-commerce-like functionality.
   
   Events
    * Events with Classy Live Engage attendees and boost fundraising worldwide
      with elevated events.
    * Event Ticketing & Registration Showcase your events and drive attendance
      with seamless registration and ticketing.
    * Auctions & Mobile Bidding Inspire attendees to give more from any device,
      in person or virtually.
   
   Community Activations
    * Peer-to-Peer Fundraising Platform Activate supporters to amplify your
      mission and fundraise on your behalf.
    * Corporate Giving Software Strengthen partnerships with a holistic menu of
      scalable, repeatable programs.

 * Platform
   Platform
    * Classy Pay Payment Processing Increase the ROI of every campaign with the
      most innovative nonprofit payment solution.
    * Donor Dashboard Empower supporters and scale retention with our
      centralized, self-serve hub.
    * Fundraising Intelligence  New Make smarter asks and predict donor behavior
      with AI and machine learning tools.
    * Integrations Hub Connect the tools you use and love with best-in-class
      integrations.
    * Campaign Templating Maintain brand consistency and scale updates across
      multiple campaigns.
    * Reporting Gain instant supporter insights and a full view of marketing and
      fundraising performance.
    * International Fundraising Engage supporters across the globe with
      multi-currency support.
    * Security and Scalability Fundraise with confidence on a platform with
      world-class security and scalability.

 * Who We Serve
   Who We Serve
    * Case Studies See how the world’s top nonprofits fuel their fundraising and
      advance their missions with Classy.
    * Nonprofits We serve thousands of innovative, U.S.-based 501(c)(3)
      nonprofits.
    * Healthcare From hospice to hospital systems, see why healthcare nonprofits
      choose Classy.
    * Churches Sustain church giving seven days a week with a platform built for
      online donations anytime, anywhere. 
    * Research & Cure Fuel your world-changing research, treatment, and cures
      with top-tier fundraising tools.
    * Food Banks Drive the funds needed to feed and serve your community with a
      comprehensive platform.
    * Human Services Power your purpose of improving lives with diverse
      fundraising solutions.
   
   Case Studies Over a Quarter of Donors Gave Multiple Gifts to City of Refuge’s
   Back-to-School Campaign See All Case Studies
 * About
   About
    * Story
    * Team
    * Impact
    * Careers
    * Pricing
   
   News Revolutionizing Fundraising: The Evolution from Gift Catalogs to Giving
   Carts
 * Resources
   Resources
    * Blog
    * Webinars
    * Partners
    * Events
    * Guides & Reports
    * Support Center
    * Classy Academy
   
   Recent 3 Fundraising Activations to Achieve Greater Giving This Year-End
   Season

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PRIVACY NOTICE

Effective Date: September 1, 2024


TABLE OF CONTENTS

 * Our Privacy Notice
 * INFORMATION WE COLLECT
 * OUR USE OF INFORMATION COLLECTED
 * OUR DISCLOSURE OF INFORMATION COLLECTED ABOUT YOU
 * VOLUNTEERED INFORMATION
 * ONLINE ANALYTICS AND TAILORED ADVERTISING
 * CHILDREN
 * LINKS TO OTHER WEBSITES
 * SECURITY
 * RETENTION OF YOUR INFORMATION
 * CROSS BORDER DATA TRANSFERS
 * USERS FROM OUTSIDE THE UNITED STATES
 * YOUR CHOICES
 * REGIONAL PRIVACY DISCLOSURES
 * OTHER TERMS
 * CHANGES TO GOFUNDME’S PRIVACY NOTICE
 * CONTACTING GOFUNDME

--------------------------------------------------------------------------------


OUR PRIVACY NOTICE

GoFundMe Group Inc. and its affiliates and subsidiaries, including Classy, Inc.
(“Classy”), GoFundMe Inc., GoFundMe Australia Pty Ltd., and GoFundMe Ireland,
Limited (collectively, “GoFundMe” “we,” “our,” and “us”) provide this Privacy
Notice (“Notice”) to explain how we collect, use, and disclose information about
you. This Notice applies to data collected by us offline and for all our
products or services on which we make this Notice available – for example, when
you use GoFundMe or the Classy Platform or our mobile applications or when you
raise funds on GoFundMe for your campaigns or donate to one of our non-profit
partners through websites powered by Classy (collectively, the “Services”).

Before you access, use, or submit any information through or in connection with
the Services, please carefully review this Notice. By using any part of the
Services, you acknowledge that you have read and understood that we may collect,
use, and disclose information about you as outlined in this Notice. To the
extent allowed by law, the English version of this Notice is binding, and its
translations in other languages are for convenience only; in case of
discrepancies between the English version of this Notice and its translations,
the English version shall prevail.

This Notice does not cover the privacy practices of either (i) organizers of
GoFundMe fundraisers (collectively, “Organizers”), (ii) beneficiaries of
fundraisers (collectively, “Beneficiaries”), or (iii) nonprofit organizations
that use the Classy platform (collectively, “Classy Clients”). We are not
responsible for the privacy practices of Organizers, Beneficiaries, or Classy
Clients, and their handling of your information may be subject to their own
privacy statements. This Notice also does not cover our data practices when we
act as a “processor” or “service provider” on behalf of Classy Clients. In those
circumstances, we process information about you on behalf of the Classy Client,
and you should consult the privacy statement of the Classy Client for
information on how they process information about you.

If you are a resident of California, the California Consumer Privacy Act of 2018
provides you with additional rights. Please view our “California Privacy Notice”
to learn more. For any other specific US state privacy law-related matters,
please refer to the section below titled “Regional Privacy Disclosures” and
“Your Choices”.


INFORMATION WE COLLECT

As further described below, we collect information in multiple ways, including
when you provide information directly to us, when we collect information about
you from other parties, and when we automatically collect information from your
browser or device (e.g., by logging how you interact with our Services).

A. Information That You Provide Directly to Us:

We and our vendors may collect information from you directly in various ways,
such as when you:

 * * * * Open an account or otherwise register for the Services;
       * Create a fundraiser on the Services;
       * Create a peer-to-peer, crowdfunding, or team page;
       * Create, register for, or purchase tickets to nonprofit events,
         merchandise, and/or other activities;
       * Set up withdrawals or transfers;
       * Donate to a fundraiser, organization, or cause;
       * Post comments, leave feedback, send thank-you notes, or otherwise
         communicate with other users through our Services;
       * Fill out a survey or questionnaire or provide us with feedback
         regarding the Services;
       * Request certain features (e.g., newsletters, updates, and other
         products);
       * Sign up for contests, awards and events hosted by us;  or
       * Communicate with us, such as for reporting a fundraiser,
         troubleshooting or support services.

The information you provide us directly may relate to you or others and may
include, without limitation:

Account Registration Information: such as your name, email address and login
details, your zip code, your country, your phone number, and certain other
information, including any information you choose to provide us (such as a
profile picture). If you use the Services as an organization (e.g., a Classy
Client or any other registered non-profit), you may also provide us with your
organization’s name, your role/title with the organization, tax identification
number, 501(c)3 or tax-exempt status, and other information about your
organization.

Fundraiser Information: such as a fundraiser title, a fundraiser category,
images, videos, description and fundraiser goal(s).

Financial Information: such as payment account details for withdrawals and
payment information for donations, and billing information. We use third-party
payment processors to process financial information. For example, we use Stripe,
Adyen and Paypal for payments, analytics, and other business services. These
payment processors may collect personal data, including via cookies and similar
technologies. The personal data they collect include transactional data and
identifying information about devices that connect to its services. They use
this information to operate and improve the services provided to us, including
fraud detection, loss prevention, authentication, and analytics related to the
performance of services. They operate both as processors for us and independent
controllers for the information they collect directly from our users.

You can learn more about Stripe and read its privacy policy at
https://stripe.com/privacy. You can learn more about Adyen and read its privacy
policy at https://www.adyen.com/policies-and-disclaimer/privacy-policy. You can
learn more about Paypal and read its privacy policy at
https://www.paypal.com/us/legalhub/privacy-full.

Publicly Available and Non-Publicly Available Communications and Content: such
as comments, feedback, thank-you notes or other communications with other users
through our Services. Any content, including such comments, feedback, and notes
that you choose to post on publicly available campaign pages through our
Services, are available to the public by default. Please remember that any
information that is disclosed in these areas becomes public information for both
us and other users to use and share. Take care not to disclose information about
you unless you intend for that data to become public. Please also be considerate
and respectful of others while using the community to publish your opinions. We
reserve the right but do not have the obligation, to review and monitor
publicly-available content, non-publicly available communications between users,
and any other content made on or through our Services, and to remove postings or
content that may be viewed as inappropriate or offensive to others.

Information about Yourself and Others, Including Sensitive Information: such as
information about a fundraiser, including the beneficiary of a fundraiser,
fundraiser goals, and other information you choose to provide, which may include
information about situations or other circumstances that motivate a fundraising
request. If you provide us with information about others, you acknowledge and
agree that you have the authority and consent of the relevant other parties for
us to access, disclose, and use the relevant data, and that you have notified
the other parties and informed them of how their information is collected and
used by GoFundMe to provide the Services. We reserve the right to identify you
as the person who has made the referral in any messages that are sent to them.
You can also provide us with information about yourself or other parties that
are considered sensitive, such as political opinions, race, ethnicity, health
information, or religious beliefs. If you post this information in a fundraiser,
you choose to provide such information to be published publicly in relation to
your fundraiser, donation, or otherwise. Subject to applicable law, GoFundMe may
process any information that has manifestly been made public, including by
processing information about you that reveals sensitive information.

Chats and Other Communications with Us: such as for troubleshooting or support
services. We may engage vendors to provide certain interactive features on our
Services. Your use of these interactive features is voluntary, and we may retain
the information that you submit through these features. For example, we may
offer an interactive chat feature on the Services for customer service purposes.
When you participate in the interactive chat, the contents of the chat may be
captured and kept as a transcript. By using these features, you understand that
we and our vendors on our behalf may, on a real-time basis, collect and process
the information obtained through the feature. We would ask that you take care
not to send financial or health information or other sensitive personal data to
us through our chat services or other means unless we ask you specifically for
that data as part of providing the Services to you. When you provide such
information to us directly, you consent to the processing of this data by
GoFundMe and/or our vendors. We collect the information listed in this section
for the purposes described below in the sections “Our Use of Information
Collected” and “Our Disclosure of Information Collected About You.”

Biometric Information: We sometimes engage vendors to collect biometric
information for identity verification, regulatory compliance, and fraud
prevention purposes. We or the vendors we engage may collect a copy of your
government-issued ID (i.e., your driver’s license, state ID card, or passport)
and a scan of the picture on your government-issued ID for identification
purposes. Our vendors may, with your consent, employ facial recognition
technology to verify your identity and share the results of their analysis with
us, if needed. GoFundMe does not have access to or otherwise collect or maintain
any biometric information. Your biometric information will be retained by our
vendors, and subject to their retention policies and privacy policies.

B. Information We Collect from Other Parties:

GoFundMe may use vendors to improve the quality of our own user database so that
we might improve our Services to you, for verification and fraud prevention
purposes, and as otherwise described in this Notice.  In addition, GoFundMe
obtains contact details and other personal information regarding media contacts
and influencers from various groups such as Cision and MuckRack. See the Cision
privacy policy and the Muck Rack privacy policy for further information.

One of the special features of the Services is that they allow you to enable or
log into the Services via various social media applications/services, like
Facebook or X, or to upload videos using YouTube APIs (each and collectively,
the “Social Networking Service(s)”). By directly integrating these Social
Networking Services, we aim to make your online experiences richer and more
personalized. To take advantage of these features, we will ask you to provide
your credentials for the applicable Social Networking Service in order to log in
to our Services. When you add a Social Networking Services account to the
Services or log into the Services using your Social Networking Services account,
we will collect the relevant information necessary to enable the Services to
access that Social Networking Service. As part of such integration, the Social
Networking Service will provide us with access to certain information that you
have provided to the Social Networking Service and made available to us based on
your privacy settings with the Social Networking Service (for example, your name
and photograph, as well as other information that you permit the Social
Networking Service to share with us).

We will use, store, and disclose such information in accordance with this
Notice. However, please remember that the manner in which Social Networking
Services use, store, and disclose your information is governed by the policies
of such third parties, and GoFundMe shall have no liability or responsibility
for the privacy practices or other actions of any Social Networking Services
that may be enabled within the Services. For example, if you upload a video onto
your fundraiser using the mobile application for the Services, your video will
be uploaded using YouTube and subject to Google’s Privacy Policy and Google’s
Security Settings. You further acknowledge that if you choose to use this
feature, your friends, followers, and subscribers on any Social Networking
Services you have enabled may be able to view such activity. For example, if you
sign on using Meta, Meta’s Privacy Policy and Terms of Service would apply to
the data Meta might obtain from your activities on GoFundMe. Please visit the
terms of use and privacy policy of the relevant Social Networking Service to
learn more about your rights and choices, and to exercise your choices about
those technologies.

C. Information That is Passively or Automatically Collected:

I. Device & Usage Information:

When you interact with GoFundMe through the Services, we automatically receive
and store certain information from devices that you use to access the Services
such as your IP address. This information is collected passively by using
various technologies and includes the type of Internet browser or mobile device
you use, any website from which you have come to the Services, your operating
system, and inferred location data through an IP address that identifies the
city and state where you logged into the Services. GoFundMe either stores such
information itself or such information is included in databases owned and
maintained by GoFundMe, and/or its agents or vendors.

II. Location Information:

When you use the Services to organize a fundraiser, the Services may require
that you provide your postcode/zip code, city or town, and state or province of
residence. Please keep in mind that other users of the Services can view your
postcode/zip code, city or town, and state or province of residence in
connection with the fundraiser. If you install our mobile application, we may
ask you to grant us access to your mobile device’s precise geolocation data. If
you grant such permission, we may collect information about your precise
geolocation, and we may use that information to improve the Services, such as
providing you with location-based features (e.g. to prepopulate your post
code/zip code or to identify fundraisers near you). We also use your location
information as described in this Notice, such as described above under “Device &
Usage Information”, and in an aggregate way, as described below in the
“Aggregated Data” section. You may opt out of providing your geolocation
information in your device’s settings.

III. Cookies and Other Electronic Technologies:

Please review our Cookie Policy for information on the types of cookies we or
our vendors use on the Services, along with how we use those cookies and other
electronic technologies.

If we are unable to collect your information, we may not be able to provide you
with the Services or assist you with your questions.


OUR USE OF INFORMATION COLLECTED

GoFundMe uses the information collected from the Services in a manner that is
consistent with this Notice. We may use the information that you provide (or
otherwise permit the Services to access) for the following purposes:

 * Provide, operate, and maintain the Services, including to register and
   maintain your account, facilitate the Know Your Customer (KYC) verification
   process and to complete transactions;
 * Communicate with you for various purposes, including to help you fundraise
   more, or for administrative purposes (e.g., to provide services and
   information that you request or to respond to comments and questions)
   regarding the Services;
 * Request your feedback;
 * Personalization, marketing, and advertising;
 * Analyze, improve, modify, customize, and measure the Services, including to
   train our artificial intelligence/machine learning models;
 * Develop new products and services and other research and development;
 * Verify your identity and to detect and prevent fraud or other misuses of the
   Services;
 * Maintain the security of your account and any associated fundraisers;
 * Comply with legal obligations, law enforcement requests and legal process and
   to protect our rights, privacy, safety, or property, and/or that of our
   affiliates, you, or other parties, including to enforce our Terms of Service
   and any other agreements; and
 * Carry out any other purpose for which the information was collected.

We may combine information that we collect from you through any or all of the
Services with information that we obtain from other sources. For example, we may
compile information from a variety of sources to generate inferences about you,
such as inferences about your likely interests in making charitable or other
donations and the potential size of such donations, starting peer-to-peer
fundraisers, signing up for recurring donations or other similar indicators.

We may also aggregate and/or de-identify information collected through the
Services. We may use and disclose de-identified or aggregated data for any
purpose, including, without limitation, research and marketing purposes.

We may communicate with you regarding your GoFundMe account by SMS, MMS, or text
message. For example, when setting up your GoFundMe account, if you click “Send
code” by “Text Message,” you agree to receive automated and nonautomated text
messages related to your account from or on behalf of GoFundMe at the phone
number provided. You can reply STOP to such text messages to cancel, except for
automated text messages related to the security of your account. Message
frequency will vary. In the event you change or deactivate your mobile telephone
number, you agree to promptly update your GoFundMe account information to ensure
that your messages are not misdirected. Please note that your wireless service
carrier’s standard charges, message and data rates, and other fees may apply
where you access the Services through a mobile device. In addition, downloading,
installing, or using certain Services on a mobile device may be prohibited or
restricted by your carrier, and not all Services may work with all carriers or
devices.

We may also employ machine learning and other analytics that make inferences
about some characteristics of our users. We use these tools to tailor emails to
you, to show and prioritize causes, fundraisers, and pages we think you’ll be
interested in, to protect you and your account from misuse, and make suggestions
about how much you may want to fundraise or donate. To opt out of this use,
please submit a request through this form.


OUR DISCLOSURE OF INFORMATION COLLECTED ABOUT YOU

There are certain circumstances in which we disclose information collected about
you with certain other parties without further notice to you, as set forth
below.

A. Business Transfers:

As we develop our business, we might sell or buy businesses or assets. In the
event of a corporate sale, merger, reorganization, dissolution, similar event,
or steps taken in anticipation of such events (e.g., due diligence in a
transaction), user information may be part of the reviewed and transferred
assets.

B. Affiliates and Subsidiaries:

We disclose your personal information among the GoFundMe entities, including our
affiliates and subsidiaries, for purposes consistent with this Notice, such as
to provide our Services, including hosting; marketing, and publicizing
fundraisers; providing you with customer support; administering funds in
connection with fundraisers; preventing fraud and misuse; authenticating donors;
sending you communications; improving Services offered by the various GoFundMe
entities and conducting the other activities described in this Notice.

C. Agents, Consultants, and Vendors:

GoFundMe contracts with other companies to help us perform certain
business-related functions, and we provide access to or disclose your
information with these companies so they can perform services for us. Examples
of such functions include marketing, mailing information, data storage,
security, identity verification, fraud prevention, payment processing,
preventing fraud and misuse, legal services, and database maintenance. Our
websites and checkout experiences for Classy Clients that are powered by Classy
are protected by reCAPTCHA and Google Privacy Policy and Terms of Service apply.

D. Legal Requirements:

We may transfer, disclose to, and preserve your information for courts, law
enforcement, governmental or public authorities, tax authorities, or authorized
third parties, if and to the extent we are required or permitted to do so by law
or where disclosure is reasonably necessary to: (i) comply with our legal
obligations, (ii) comply with a valid legal request (such as a subpoena or court
order), (iii) respond to claims asserted against us, (iv) respond to a valid
legal request relating to a criminal investigation to address alleged or
suspected illegal activity or to respond to or address any other activity that
may expose us, you or any other of our users or members of the public to
imminent harm, legal or regulatory liability, (v) enforce and administer our
Terms of Service or other policies, or (vi) protect the rights, property or
personal safety of GoFundMe, its affiliates, its employees, its users, or
members of the public.

E. Organizers, Nonprofit Beneficiaries, and Classy Clients:

Organizers. We may disclose your information to Organizers, which may or may not
be the same as the Beneficiaries of the fundraiser. For example, if you donate
to a fundraiser for an individual, we may disclose your name and donation amount
to the Organizer who may in some instances also be the Beneficiary. Likewise, if
you donate to a nonprofit through Classy, you direct us to disclose your
donation, contact information and any other information you provide to the
applicable nonprofit.

Nonprofit Beneficiaries. Organizers may create fundraisers designating a
nonprofit organization as a Beneficiary. Where a nonprofit organization is
designated as the Beneficiary, that nonprofit organization may access certain
information about the Campaign Organizer and donor information, including the
donor’s name, email address, donation amount, date of transaction, transaction
identification number, and name of the campaign. GoFundMe contractually requires
the nonprofit organization to use such information solely to communicate with
you about your donation and for legal and auditing requirements. GoFundMe may
authorize nonprofit organizations to process your information for other purposes
(such as marketing) if you opt-in to that processing.

Classy Clients and Their Vendors/Partners. Classy may power the donation pages
and other activities, such as event hosting for Classy Clients. If you donate to
a nonprofit through a Classy-powered webpage, you direct us to disclose your
donation and contact information to the applicable nonprofit, and such
information shall also be subject to the privacy policies and practices of that
Classy Client. Classy Clients may also direct us to further disclose your
personal information to other third parties such as CRM tools or other
integration partners used by the relevant Classy Client. We may also disclose
certain information about you, such as information about your interests and
donation preferences, to Classy Clients who may use such data for their
fundraising and marketing operations.

“Anonymous” Donations Limited to Public Activity Feeds. If you selected not to
be named publicly on the public fundraiser pages on the Services, while your
donation will be designated as “anonymous” on the public activity feed, your
name and other information may still be visible to the Classy Client, Organizer,
any of their team members and the Beneficiary, and will be otherwise processed
in accordance with this Notice.

F. Your Consent

In certain situations, we may disclose your information when you consented to
the disclosure of your information. For example, we may partner with third party
organizations to arrange for specific fundraisers. If you consent to our
providing your contact information to a specific partner, we will disclose the
following information with the partner organization: your name, email address
and other information you have provided in connection with your donation to the
specific fundraiser. Additionally, with the applicable Organizer’s or
Beneficiary’s consent, we may provide their personal information to journalists
and media to help amplify a campaign.

G. Aggregated Data

We aggregate, anonymize and/or de-identify information collected actively or
passively about you so that the information no longer relates to you
individually.  We then use that data for various legally permissible purposes,
including but not limited to our research on our customer demographics,
interests and behavior. We also disclose this information with our affiliates,
agents, business partners, research facilities or other third parties.

H. Cookies and Other Electronic Technologies

Information is disclosed as stated in the Cookie Policy.

I. Other Users of Our Services

We provide your information to other users of our Services if you choose to make
your information publicly available in a publicly accessible area of the
Services, such as in your fundraiser through your donations or in the comments.


VOLUNTEERED INFORMATION

Please be advised that some information you provide may be publicly accessible,
such as information posted in forums or comment sections. When you launch a
fundraiser, you make certain information publicly available and thus not
protected by certain data protection laws. We also collect information through
forums and communities, surveys and customer support communications, your
communication to us of ideas for new products or modifications to existing
products, feedback, and other solicited or unsolicited submissions
(collectively, with publicly-accessible information, “Volunteered Information”).
Subject to applicable law, by sending us Volunteered Information, you further
agree that we are under no obligation of confidentiality, express or implied,
with respect to the Volunteered Information. This Volunteered Information
section shall survive any termination of your account or the Services.


ONLINE ANALYTICS AND TAILORED ADVERTISING

Analytics. We may use third-party web analytics services on the Services, such
as those of Google Analytics. These vendors use the sort of technology described
in the “Information That is Passively or Automatically Collected” section above
and in our Cookie Policy to help us analyze how users use the Services,
including by noting the third-party website from which you arrive. The
information collected by such technology will be disclosed to or collected
directly by these vendors, who use the information to evaluate your use of the
Services. We also may use Google Analytics for certain purposes related to
advertising, as described in the following section. To prevent Google Analytics
from using your information for web analytics, you may install the Google
Analytics Opt-Out Browser Add-on.

Tailored Advertising. We may allow third-party advertising networks to place
cookies or other tracking technologies on your computer, mobile phone, or other
device to collect information about your use of the Services in order to (a)
inform, optimize, and serve marketing content based on past visits to our
website and other online services and (b) report how our marketing content
impressions and interactions with these marketing impressions are related to
visits to our online services. We may also allow other unaffiliated parties
(e.g., ad networks and ad servers such as Google Analytics) to serve tailored
marketing to you and to access their own cookies or other tracking technologies
on your computer, mobile phone, or other device you use to access the Services.
Those parties that use these technologies may offer you a way to opt out of
targeted advertising as described below. You may receive tailored advertising on
your computer through a web browser. Cookies may be associated with
de-identified data linked to or derived from data you voluntarily have submitted
to us (e.g., your email address) that may be disclosed to a vendor in hashed,
non-human-readable form.

We may use certain Meta products, such as the Meta Conversion API, on our
Services (see our Cookie Policy for further information regarding digital
advertising and cookies and similar technologies). We may use the product for
certain analytics and marketing purposes as described in this Notice, including
for measuring the effectiveness of Facebook ads for statistical and market
research purposes. Meta Platforms Ireland Limited (“Meta”) acts as a joint
controller of processing with GoFundMe within the scope of the General Data
Protection Regulation for certain of the processing activities relating to
marketing and ad measurements. Information about how Meta processes your
information, the legal basis for the processing, and how to contact Meta to
exercise your rights with regard to information stored by Meta can be found at
https://www.facebook.com/about/privacy.

If you are interested in more information about tailored advertising and how you
can generally control cookies from being put on your computer to deliver
tailored marketing, you may visit the Network Advertising Initiative’s (“NAI”)
Consumer Opt-Out Link, the Digital Advertising Alliance’s (“DAA”) Consumer
Opt-Out Link, and/or the European Interactive Digital Advertising Alliance to
opt-out of receiving tailored advertising from companies that participate in
those programs. To exercise choices about how Google personalizes Display
Advertising or to customize Google Display Network ads, you can visit the Google
Ads Settings page. Please note that to the extent advertising technology is
integrated into the Services, you may still receive advertising content even if
you opt out of tailored advertising. In that case, the advertising content may
not be tailored to your interests. Also, we do not control any of the above
opt-out links and are not responsible for any choices you make using these
mechanisms or the continued availability or accuracy of these mechanisms. If
your browsers are configured to reject cookies when you visit these opt-out
pages, or you subsequently erase your cookies, or use a different computer or
change web browsers, your opt-out may no longer be effective.


CHILDREN

Our Services are not designed for use by individuals under the age of 13 (or 16
for children located in the European Economic Area or United Kingdom). If you
are under the age of 13 (or 16 for children located in the European Economic
Area or United Kingdom), please do not use the Services and/or submit any
information through the Services. If you have reason to believe that a child
under the age of 13 (or 16 for children located in the European Economic Area or
United Kingdom) has provided personal information to GoFundMe through the
Services, please contact us at GFMlegal@gofundme.com, and we will delete that
information from our databases to the extent required by law.

Moreover, if you provide us with information about children under the age of 16,
you acknowledge and agree that either you are the child’s parent/legal guardian
or you have the authority and consent of the child’s parent/legal guardian to
create a campaign/fundraiser and for us to access, disclose, and use the
relevant data.


LINKS TO OTHER WEBSITES

The Services can contain links to other web sites not operated or controlled by
GoFundMe (the “Third-Party Sites”). The policies and procedures we described
here do not apply to the Third-Party Sites. The links from the Services do not
imply that GoFundMe endorses or has reviewed the Third-Party Sites. We suggest
contacting those sites directly for information on their respective privacy
policies.


SECURITY

We may hold your information we have collected in paper and/or electronic form.
While no organization can guarantee perfect security, GoFundMe has implemented
and seeks to continuously improve technical and organizational security measures
to protect the information provided via the Services from loss, misuse,
unauthorized access, disclosure, alteration, or destruction. Please see here for
details about security for gofundme.com and here for details about Classy’s
platform.


RETENTION OF YOUR INFORMATION

We retain your information for as long as we deem necessary for the purpose for
which that information was collected and for our legitimate business operations;
provided, however, that your information is only retained to the extent
permitted or required by applicable laws. When determining the retention period
for your information, we take into account various criteria, such as the type of
products and services requested by or provided to you, the nature and length of
our relationship with you, possible re-enrollment with our products or services,
the impact on the Services we provide to you if we delete some information about
you, mandatory retention periods provided by law, and any applicable statute of
limitations.


CROSS BORDER DATA TRANSFERS

GoFundMe is a global organization headquartered in the United States, and we may
process your information in various countries, including the United States,
India, and Argentina. GoFundMe has implemented appropriate cross-border transfer
solutions, to provide adequate protection for transfers of certain personal data
to the United States, such as execution of the Standard Contractual Clauses for
transfers of data from the European Economic Area, United Kingdom, and
Switzerland to the United States.


USERS FROM OUTSIDE THE UNITED STATES

The Services are hosted in the United States. If you are visiting the Services
from outside the United States, please be aware that your information may be
transferred to, stored, and processed in the United States and other locations
such as Argentina and India where our servers and personnel are located, and our
central database is operated. The data protection and other laws of the United
States and other countries might not be as comprehensive as those in your
country, and data may be accessible to law enforcement and national security
authorities under certain circumstances.


YOUR CHOICES

We offer you certain choices regarding the collection, use, and disclosure of
information about you.

Account Information. You may have the ability to create an account in the
Services. You may verify, correct, update, or delete certain of your information
through your account profile page.

Marketing Communications. Each email marketing communication we send you will
contain instructions permitting you to “opt out” of receiving future marketing
communications. In addition, if at any time you wish not to receive any future
marketing communications or you wish to have your name deleted from our mailing
lists, please contact us at the email address or mailing address set forth under
“Contacting GoFundMe.” If you opt out of receiving marketing communications or
other information we think may interest you, we can still send you certain
emails about your account or any Services you have requested or received from
us.

Cookies and Analytics. You can opt out of certain cookie-related and analytics
processing by following the instructions in this Notice.

Rights to Information About You. Your local law may provide you with certain
rights with respect to your information. Depending on your jurisdiction, you may
request that we:

 * * Provide you with information about the categories of personal information
     we collect or disclose about you; the categories of sources of such
     information; the business or commercial purpose for collecting such
     information; and the categories of unaffiliated parties to whom we disclose
     such personal information. Such information is also set forth in this
     Notice;
   * Provide access to and/or a copy of certain information we hold about you;
   * Prevent the processing of your information for direct-marketing purposes
     * (including any direct marketing processing based on profiling);
   * Update information which is out of date or incorrect;
   * Delete certain information that we are holding about you;
   * Restrict the way that we process and disclose certain information about
     you;
   * Transfer your information to a third-party provider of services;
   * Opt you out of the processing of your personal information for purposes of
     profiling in furtherance of decisions that produce legal or similarly
     significant effects, if applicable; and
   * Revoke your consent for the processing of your information provided that
     the withdrawal of consent shall not affect the lawfulness of the processing
     based on consent before its withdrawal.

You may be able to designate an authorized agent to make requests on your
behalf. In order for an authorized agent to be verified, you must provide the
authorized agent with signed, written permission to make such requests or a
power of attorney. We may also follow up with you to verify your identity before
processing the authorized agent’s request as permitted by applicable law.

Please note that certain information may be exempt from such requests under
applicable law. For example, we may retain certain information for legal
compliance and to secure our Services. We also may need certain information in
order to provide the Services to you; if you ask us to delete it, you may no
longer be able to use the Services.

You also have the right not to be discriminated against (as provided for in
applicable law) for exercising your rights.

You may also have the right to opt out of sales of your personal information, or
the processing of your personal information for targeted advertising. To opt out
of any future targeted advertising we may offer, please use the tools described
in the section above on Online Analytics and Tailored Advertising, or in our
Cookie Policy. We may “sell” information about you to certain partners such as
nonprofit organizations to help them understand your likely interests in making
charitable or other donations, the potential size of such donations, or your
interests in starting peer-to-peer fundraisers, signing up for recurring
donations or other similar indicators. To opt out of “sales” of your personal
information that do not involve cookies or other online tracking technologies,
please complete this form.

If you would like information regarding your rights under applicable law or
would like to exercise any of them, contact us at the email address or mailing
address set forth under “Contacting GoFundMe.” For your own privacy and
security, at our discretion, we may require you to provide your identity before
providing the requested information. To protect your privacy and security, we
take reasonable steps to verify your identity and requests before granting such
requests. If we are unable to verify your identity, we may be unable to respond
to your requests.

Depending on applicable law, if we deny your request, you may have the right to
appeal our decision to deny your request. We will provide information about how
to exercise that right in our response denying the request.

Regional Privacy Disclosures and Rights. Additional disclosures for residents of
the European Economic Area, Australia, United Kingdom, Switzerland, California,
Colorado, and Nevada are set forth below in Regional Privacy Disclosures.


REGIONAL PRIVACY DISCLOSURES


USERS IN EUROPE AND UNITED KINGDOM

If you are in the European Economic Area (“EEA”), the United Kingdom or
Switzerland (collectively “Europe”) and have used the GoFundMe Services under a
contractual relationship under the Terms of Service with GoFundMe Ireland, then
for the purposes of the EU General Data Protection Regulation 2016/679 (the
“GDPR”), the UK GDPR , and the Swiss Federal Act of 19 June 1992 on Data
Protection (FADP) and the Privacy and Electronic Communications Directive
2002/58/EC on Privacy and Electronic Communications (ePrivacy Directive), the
data controller is GoFundMe Ireland Limited. and can be reached at the address
set out at “Contacting GoFundMe” below; and

 * For the Users in the EEA that do not fall under the previous paragraph, and
   to the extent that this would be required by GDPR, GoFundMe Ireland also acts
   as representative in the EU of GoFundMe Inc.

If you are located in Europe, our legal grounds for processing your information
may be as follows:

 * * Consent: Where you have given consent to such processing for one or more
     specific purposes.
   * Contractual Obligation: Where the processing is necessary for the
     performance of a contract with you.
   * Legal Obligation: Where processing is necessary for compliance with our
     legal obligation.
   * Legitimate Interest: Where processing is necessary for our legitimate
     interests or the legitimate interests of our users and your interests and
     fundamental rights and freedoms do not override those interests.

We transfer your personal data to third countries subject to appropriate
safeguards, such as standard contractual clauses.

Residents of Europe also have the right to lodge a complaint with the local data
protection authority if you believe that we have not complied with applicable
data protection laws. You also have the right to lodge a complaint with the
supervisory authority of your residence, place of work or where the incident
took place. However, we encourage you to contact us first, and we will do our
very best to resolve your concern.

The Irish Data Protection Commissioner shall act as the competent lead
supervisory authority for users in the European Economic Area, and you have the
right to lodge a complaint with your local data protection authority (see list
in the link
https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.) 
The Information Commissioner’s Office shall act as the competent supervisory
authority for users in the United Kingdom and the Data Protection and
Information Commissioner (FDPIC) for Switzerland.


USERS IN AUSTRALIA

If you are a user in Australia, you also have the right to lodge a complaint
with the local data protection authority if you believe that we have not
complied with applicable data protection laws, and you have the right to lodge a
complaint with the supervisory authority of your residence, place of work or
where the incident took place. However, we encourage you to contact us first,
and we will do our very best to resolve your concern.


RESIDENTS OF NEVADA

If you are a resident of Nevada, you have the right to opt-out of the sale of
certain personal information to unaffiliated parties. You can exercise this
right by contacting us as described in the “Contacting GoFundMe” section below
with the subject line “Nevada Do Not Sell Request” and providing us with your
name and the email address. We do not currently sell your personal information
as sales are defined in Nevada Revised Statutes Chapter 603A.


RESIDENTS OF COLORADO

Please click here for additional disclosures about the purposes for which we use
each category of information we collect from and about you.


RESIDENTS OF CALIFORNIA

Please click here for additional disclosures applicable to residents of
California.


OTHER TERMS

Your access to and use of the Services is subject to GoFundMe’s Terms of Service
and such other terms, which may be made available to you in connection with your
use of the Services.


CHANGES TO GOFUNDME’S PRIVACY NOTICE

GoFundMe reserves the right to update or modify this Notice at any time and from
time to time. We will notify you of any material updates or changes we make to
this Notice. If you disagree with our revisions to the Notice, you can
deactivate your account or discontinue the use of our Services. Please review
this Notice periodically for any updates or changes to this Notice.

By using the Services after any such update or modification, you acknowledge
that you have read and understood the terms of the Notice as updated or
modified.


CONTACTING GOFUNDME

You can contact our Data Protection Officer by emailing dpo@gofundme.com.

To submit a Data Subject Request, please fill out this form or email
privacy-requests@gofundme.com.

You can also contact us via mail or phone as follows:

For users in the USA and the rest of the world (except Europe):

GoFundMe Inc. and Classy, Inc.
℅ Legal Department
PO Box 121270
815 E Street
San Diego, CA, 92101
United States

Ph: +1 (408) 915-7998

For users in Europe:

GoFundMe Ireland, Limited,
℅ Legal Department
70 Sir John Rogerson Quay,
Dublin 2, Ireland.

Prior version of our Privacy Notice available here.




PRIVACY POLICY

Effective Date: 2/6/2023
Archived Versions can be found here.


OVERVIEW

At Classy, Inc. and Classy Holdings, Inc. (collectively, “Classy”, “us”, “we”,
“our”), we value your privacy and are dedicated to safeguarding your personal
information. Classy is a social enterprise that creates world-class online
fundraising software for nonprofits, modernizing the giving experience to
accelerate social impact around the world. Classy also hosts the Collaborative
conference and the Classy Awards to spotlight the innovative work nonprofits are
implementing around the globe.

In this Privacy Policy (“Policy”), we describe the personal information we
collect from visitors to and users of our websites, including those webpages
enabling donations to clients using our platform and webpages supporting Classy
Live) (“Sites”); our mobile applications (“Applications”); and our online
products and services, including application programming interface integrations
and widgets that we offer (“Services”) and how we collect, use, share, and
disclose personal information in the course of our business activities,
including:

 * OVERVIEW
 * WHAT INFORMATION DO WE COLLECT ABOUT YOU AND WHY?
 * HOW DO WE USE YOUR INFORMATION?
 * WHEN AND HOW DOES CLASSY SHARE INFORMATION IT RECEIVES?
 * HOW SECURE IS INFORMATION ABOUT ME?
 * CAN I ACCESS AND MODIFY MY PERSONAL INFORMATION?
 * WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?
 * INTERNATIONAL DATA TRANSFER
 * CHILDREN UNDER 13 (AND UNDER 16 IN THE EU)
 * TERMS OF SERVICE
 * SPECIAL INFORMATION FOR CALIFORNIA RESIDENTS
 * SPECIAL INFORMATION FOR VIRGINIA RESIDENTS
 * CHANGES TO THIS POLICY
 * CONTACT US

By visiting our Sites or using any of our Applications or Services, you agree
that your personal information will be handled as described in this Policy,
which is incorporated by reference into the Classy Terms of Service, available
at https://www.classy.org/terms/. It is important to note that not all aspects
of this Policy may apply to you, depending on the types of interactions you have
with us and the categories of personal information that we collect from you.
Those activities will determine which of the following applies to you and your
personal information. If you have  questions or complaints regarding this Policy
or our privacy practices, please contact us at privacy@classy.org.

If you are a resident of California, the California Consumer Privacy Act of 2018
provides you with additional rights. Please view the “Special Information for
California Residents” section of this Policy to learn more. If you are a
resident of Virginia, the Virginia Consumer Data Protection Act provides you
with additional rights. Please view the “Special Information for Virginia
Residents” section of this Policy to learn more.

 


WHAT INFORMATION DO WE COLLECT ABOUT YOU AND WHY?

We collect information from you so that you can log onto our Sites and use our
Services and Applications. These activities provide you with the opportunity to,
(1) if you are an individual consumer, donate to your favorite organizations and
causes, create a peer-to-peer fundraising or team page, and/or register for or
purchase tickets, events, reservations, merchandise, and/or other activities;
and (2) if you are a client of Classy, set up peer-to-peer or crowdfunding
efforts, create donation pages, set up registration on your own behalf or for
your organization’s own supporters for events, tickets, transactions, sales,
reservations, and/or activities (collectively, “Campaigns”). We also collect
information from businesses, organizations, and individuals who request
information from Classy or apply to Classy’s job postings.

Individuals (and agents of individuals) who provide us information directly or
indirectly by donating to or participating in a Campaign or by otherwise using
our Services in an individual capacity are referred to herein as “Consumers.”
For example, Consumers may enter information in order to donate to a Campaign,
or someone who has organized a team as part of a Campaign may enter your
information on your behalf to register your entire team for an event. In
addition, individuals or organizations can use our Services to set up Campaigns
in order to provide Consumers the opportunity to donate, participate, create
peer-to-peer fundraising campaigns, or otherwise interact with such Campaigns
(those who use our Services to provide these opportunities to Consumers,
primarily charities or other nonprofit organizations, are referred to as
“Clients”). Relatedly, our Clients (including agents or representatives of our
Clients) may provide us personal information about individuals who have
registered for a Campaign being operated by our Client or who the Client wants
us to contact or otherwise provide Services to on behalf of the Client.

When you participate in a Client’s Campaign, we provide your personal
information to the Client. This Policy does not cover our Clients’ use of your
personal information outside of our Services. We are not responsible for the
privacy practices of our Clients, and as such we encourage you to read their
respective privacy statements. Further, you may be presented with opportunities
to purchase products or services offered by other parties or you may elect to
participate in contests or sweepstakes offered or sponsored by third parties on
the Site. We are not responsible for any such purchase you make, or
participation you undertake, and as such any such purchase or participation will
be subject to the relevant party’s terms and conditions. When Clients or
Consumers contact us for support or other customer service requests, we maintain
support tickets and other records related to the requests, including any
information provided by such individuals related to such support or service
requests. We may also collect call recordings related to support, customer
service, and sales-related calls.

INFORMATION WE COLLECT DIRECTLY FROM YOU AND HOW IT MAY BE SHARED OR DISCLOSED

Account Information for our Sites. You may browse our Sites without creating an
online account or providing us with your information, but to use certain
features or to participate in certain Campaigns, you may need to create an
account or otherwise provide us with information. When you create an account
with us or participate in a Campaign, we may ask you to provide the following:

 * Your first and last name;
 * Your physical address for billing purposes;
 * Your email address and your desired password;
 * Your display name (this is the name other people will see when you post items
   to one of our Sites, make a publicly visible donation, or engage in other
   similar activities on our site);
 * Your date of birth;
 * Your marketing preferences (whether and what types of information you would
   like us to send you);
 * Information about your activities and interests;
 * Other profile data, such as contact information, occupation, gender, and
   photos;
 * Other data requested by Clients using custom question fields;
 * The contact information of a friend, other members of your team, or your
   customers (when inviting them to visit the Site or when you are allowed to
   set up an account for them);
 * Activity data such as your donation history, fundraising history, events
   attended, etc.;
 * Your name, contact information, and financial information, when you
   participate in a Campaign;
 * Your organization’s name, tax identification number, title, 501(c)3 or
   tax-exempt status, and other information about your organization, if you are
   a Client or prospective client;
 * Credit reports, if you are applying for a sub-merchant account; and
 * Payment information, such as credit card or financial account numbers (if
   applicable).

Creating a Client Account. We automatically create an account profile for each
Client that registers with the Sites. This profile displays the Client’s active
Campaigns. It also displays the total amount the Client has raised through the
Sites and total number of supporters. Each account profile may include an
activity feed that displays activity occurring on the Sites related to that
Client (e.g., donations made, events posted, etc.). These account profiles may
be publicly accessible using the search function within the Sites or by external
search engines (unless, where the functionality is available, the account
profile has been made “private” by the Client).

Consumer Transactions. When you make a transaction through the Sites, we
automatically index it for you in an individual profile specific to you. That
information remains hidden from the public. If you activate your profile, then
you will be able to see your profile when you are logged in. The information in
your profile remains inaccessible to the public after you activate it; in order
to prevent unauthorized access to your profile, you should not disclose or share
your login information with other people.

Donations. When you make a donation via the Sites, other Services, or a partner
website that uses Classy’s donation processing services, you may be asked to
share certain information with the recipient charity(ies), including your credit
card/financial information and contact information. When a Consumer has asked to
remain anonymous, this only hides your name from public activity feeds, not the
underlying charitable beneficiary. If you make a donation to an individual
fundraiser (i.e. via a peer-to-peer page) but do not donate anonymously, then
the person who created the fundraising page will also have access to your
personal information (except for your credit card number or financial
information). If you make a donation through an individual fundraising page
associated with a fundraising team, or directly to a team fundraising page, then
the team fundraising captain will also have access to your personal information
(again, except for your credit card number or financial information).

Login and Location Information for Our Mobile Applications for Consumers. When
you first visit any of our mobile Applications, you may have the option of
creating a user ID and password for subsequent visits. When you log into certain
of our Applications, we may request your permission to obtain your current
location (so-called “geolocation” information) so that we can identify Campaigns
near you or to provide other location-related services. In the “settings”
function on your phone, you will have the ability to manually permit or preclude
us from recording your geolocation information for certain Applications or
features of Applications.

Charitable Campaigns/Fundraising. If you are a Client, you may create a variety
of different types of pages on our Sites in connection with your Campaigns
(“Client Pages”). Likewise, if you are a Consumer, you may create one or more
pages on certain of our Sites in connection with (i) your participation in a
Campaign (e.g., you want to raise money for running in a marathon), (ii) your
support of a particular charity, (iii) your registration to an event, or (iv)
for other purposes (collectively, “Consumer Pages”). We may collect information
from you in the process of your creation of these Client Pages or Consumer
Pages, as well as in connection with your creation of, administration of, or
participation in, a Campaign.

Public Campaigns. Any Campaign (including all associated Client Pages and
Consumer Pages) will be publicly available unless it is set to “private” (or
similar designation), where that functionality is made available, by the Client
responsible for creating the Campaign (see below for an explanation of “Private
Campaigns”). Unless set to “private” or similar designation, where that
functionality is made available, all such Campaign pages created on the Sites
are indexed by search engines and accessible to the public. Information that you
post on event pages, campaign pages, personal fundraising pages, or other public
pages on the Sites can be accessed by other people. You should exercise caution
when deciding to disclose information on public pages. We cannot control who
accesses disclosed information or how other parties will use that information.

Private Campaigns. If you, as a Client, create a Campaign on the Sites and
select the “private” (or similar) setting, where that functionality is made
available, this means that the Campaign link will not be displayed through the
activity feeds on the Sites, the Campaign will not be available through the
internal search function on the Sites, and neither it nor any associated
Consumer pages will be indexed by external search engines like Google. It does
not mean, however, that people cannot still wind up on these pages (e.g., if the
link is shared with them).

User Profiles, Comments, and Posts. Some of our Sites and Applications allow
users to create or post content, such as comments, blogs, and messages. If you
provide content to our Sites, we may collect and use that information as
described in this Policy. Please note that such information may be viewed,
collected or used by other registered users and public visitors to our Sites.
Once posted, we cannot control how such information is used and therefore cannot
prevent such information from being used in a manner that may violate the law,
or your personal privacy. As a Consumer, your user profile, however, may offer
privacy settings within your account to help you manage how your content is
displayed.

Social Impact Data. Some of our Sites and Applications allow Clients to post
content about their nonprofit programs and performance, including data about
program strategy, operations, financials, results, and growth tactics. If you
provide content to our Sites, we may collect and use that information as
described in this Policy. Please note that such information may be viewed,
collected, or used by other registered users and public visitors to our Sites.
Contests, Surveys, and Questionnaires. When you sign up for contests, including
the Classy Awards, or complete questionnaires or surveys, we collect the
information you submit to us. We use this information to administer the contest,
or survey to analyze the results, for research purposes, to send you other
information or offers we think may be of interest to you (pursuant to your
consent if required by law), to comply with legal requirements, and for other
purposes as discussed in this Policy. This information, such as impact and
financial data, may be shared with Partners (as defined below) to appear on
their websites and may also be published and used by Classy.

Job Site References. As part of applying for employment with Classy, we may ask
you for information such as details regarding your education, employment
history, qualifications, and the contact information of a former colleague’s
name. This information is used for job reference purposes only and is not used
for any other purpose.

Information We Collect from Facebook. We may provide you with the opportunity to
connect via Facebook, through our Sites or Applications. For example, you can
indicate that you are going to participate in a Campaign and invite your
Facebook friends to join that Campaign. If you log into Facebook through our
Sites or Applications, we will request permission to (i) access your basic
information, which includes your name, profile picture, networks, Facebook user
ID, list of friends and any other information that you have made public on
Facebook; and (ii) manage your participation in Campaigns. For information about
how Facebook may disclose your information, including any information you make
public, please consult the Facebook Data Use Policy. We have no control over how
Facebook uses or discloses the personal information you provide to it. We store
the information that we receive from Facebook along with other information that
we collect from you or receive about you.

Information We Collect About You from Third Parties. We also may collect
information, including personally identifiable information, about you from our
affiliates and non-affiliated third parties. For example, if you register for a
race by clicking through our Sites, we may obtain your race time when the race
is over.

Information We Collect Automatically. We may use cookies, web beacons, tags,
scripts, and other automated devices to collect information, including
personally identifiable information, about you when you visit our Sites and
receive emails from us. Specifically, we may collect the following information
about your use of our Sites via these technologies: your browser type and
operating system; web pages you view; webpage interaction, including cursor
movement and links you click; your Internet Protocol (“IP”) address; your
approximate geographic location; your interaction with the Sites; length of time
you are logged in to our Sites; your unique ID which is given to each visitor
and expiration of date of the ID and websites visited before or after our Sites.
In some of our email messages, we use a “click-through URL” linked to content on
the Classy website. When Consumers click one of these URLs, they pass through a
separate web server before arriving at the destination page on our Site. We
track this click-through data to help us determine interest in particular topics
and measure the effectiveness of our Consumer communications. If you prefer not
to be tracked in this way, you should not click text or graphic links in the
email messages. We also collect non-personal data (including, without
limitation, of the type set forth above) from third parties. The information we
collect from third parties may be combined with the information we collect
directly. This information also may be associated with your username and
combined with other information, including personally identifiable information
that we collect about you.

This data allows our Sites and Applications to function properly, including, by
ensuring the proper display of content; creating and remembering your account
login details; interface personalization; improving our Sites; and securing our
Sites and protecting against fraud. This data is also used to run statistics to
avoid visitors being recorded twice, to understand users’ reaction to our
advertising campaigns, to improve our offers, to provide a mechanism to share
content on social media, to show online advertisements for products that may be
of interest to you (based on your previous behavior), and/or ads and content on
social media platforms or other sites. For more detailed information on our use
of cookies and other tracking technologies, please see our cookie policy here.

Information Collected by Clients. Our Clients may place cookies or other
tracking technologies on your computer, mobile phone, or other device to collect
information about your use of the Sites related to that particular Client.
Please refer to that party’s privacy policy if you have any questions about its
use of your information.

Credit Card Information. As noted above, Classy collects credit card information
through its payment processor when you enter into certain types of transactions
requiring payment. Credit card information collected by Classy undergoes a
tokenization process performed by our vendor and is not stored by Classy
directly. The information is only used to perform the transaction and any
recurring or guaranteed minimum transactions to which you have agreed.

 


HOW DO WE USE YOUR INFORMATION?

We may use the information that we gather about you for the following purposes:

 * To provide our Services to you, to communicate with you about your use of our
   Services, and for other customer service purposes;
 * To provide information that you have requested to receive from us in response
   to your opt-in requests;
 * To provide our Services at the request of our Clients;
 * To administer Campaigns;
 * To administer your account;
 * To send you receipts;
 * To provide and post results of Campaigns;
 * To respond to customer service inquiries;
 * To improve our Sites and Services by providing personalized experiences,
   location customization, personalized help, and instructions;
 * To provide you updates about our Sites and Services;
 * For marketing and advertising purposes; for example, we may use your
   information to display targeted advertisements to you on our Sites and to
   assist us in advertising our Services on third party websites;
 * To send you email, follow-up questions about your Campaign or your
   participation in a Campaign, news and newsletters, promotions, and/or
   invitations to visit the Site;
 * To fulfill your request to participate in a webinar or Classy event;
 * To conduct the Classy Awards or other promotions you have entered;
 * To better understand how users access and use our Sites and Services, both on
   an aggregated and individualized basis, and for other research purposes;
 * When you, if a Consumer, submit your contact information to sign up for or
   activate a Classy profile, you agree and consent that Classy may send you
   communications relating to our products, events, or recommended charities or
   Campaigns (unless such communication requires consent according to applicable
   law and subject to your ability to opt out of such communications); and
 * When you, if a potential Client, submit your organization’s contact
   information to sign up for an account with Classy, you agree and consent that
   Classy may send your organization communication relating to our products,
   events, or other business information (unless such communication requires
   consent according to applicable law and subject to your ability to opt out of
   such communications).

Clients should note that we may use information we receive or collect regarding
Consumers (including without limitation via a Campaign page) in accordance with
the terms of this Policy, including in the manner set forth above.

Notwithstanding the foregoing, in certain contexts, we collect information on
behalf of our Clients subject to contractual requirements that limit our ability
to use and transfer your information in ways that are more restricted than those
in this Policy (e.g., the information be only used as necessary to provide
Services to the Client and/or for other specified purposes). In those limited
circumstances, your information is subject to those contractual requirements to
the extent that they conflict with this Policy, subject to enforcement by the
applicable Client. If your information is collected on behalf of another party,
such as a Client, it will be evident at the time that you provide such
information. This Policy does not cover our Clients’ use of your information
outside of our Services. You should contact the Client or other party directly
to determine if your information is subject to such limitations on uses and to
ascertain how the other party will make use of your information.

 


WHEN AND HOW DOES CLASSY SHARE INFORMATION IT RECEIVES?

Third Parties. We may share your information, including personally identifiable
information, with unaffiliated and affiliated third parties.

Affiliates. We may disclose the information we collect from you to our
affiliates or subsidiaries.

Campaign Sponsors or Partners. If you are using our Services to participate in a
Campaign or to purchase another party’s product or service, Classy shares the
personal information that you provide with the applicable parties in order to
fulfill your request. You may receive communications, correspondence, emails, or
direct mail from these entities; each such party operates independently from
Classy and is not subject to this Policy but is subject to its own privacy
policy. For example, if you donate to an organization, that organization may
reach out to you to inform you how your donation was used or otherwise thank
you. In some instances, we allow Clients to use our email system via the
Services to contact Consumers for their current and past Campaigns, so you may
receive emails from our system that originate with such Clients. Please refer to
that party’s privacy policy if you have any questions about its use of your
information.

Activity Feeds. Activity feeds are streamed displays of actions occurring on the
Sites. Unless you select the option to participate in a Campaign anonymously,
your name and the amount of your contribution (or ticket/registration purchase)
will be publicly displayed through the relevant Client’s activity feed and the
activity feed of a fundraising or team page.

Clients using the Sites also have access to certain widgets (widgets are small
snippets of code we generate that the Client can then put into another website).
These widgets allow Clients to display activity occurring on the Sites on the
Clients’ own websites, blogs, or another website. Unless you donate anonymously,
your name and the amount of your donation (or ticket/registration purchase) may
be publicly displayed through the activity feed on a widget. If you become a
supporter of a Client on the Sites, or fundraise for a Client on the Sites, your
name and picture may also be displayed on a widget. Please keep in mind that we
cannot control where a given Client will embed the widgets we make accessible to
it.

Making a donation “anonymous” only hides your name from public activity feeds,
not the underlying charitable beneficiary. If you donate anonymously through a
personal or team fundraising page, your personal information will not be shared
with either the individual fundraiser or the team fundraising captain. If you
make a donation to an individual fundraiser (i.e., via a peer-to-peer
fundraising Campaign) but do not donate anonymously, then the person who created
the fundraising page will also have access to your personal information (except
for your credit card number or financial information). If you make a donation
through an individual fundraising page associated with a fundraising team, or
directly to a team fundraising page, then the team fundraising captain will also
have access to your personal information (again, except for your credit card
number or financial information). Similarly, if you join a team to participate
in a Campaign, such as a race or other event, then the team captain will also
have access to your personal information (again, except for your credit card
number or financial information). You consent to the foregoing and agree that we
are not responsible for how these organizations or persons handle your personal
information. You should visit their websites and/or contact them directly for
their privacy policies and data usage practices.

Supporter Communications. As part of a Client’s use of the Services, Consumers
may also send emails through the Services. For example, personal fundraisers may
send messages to their contacts through the Services in order to ask people to
visit their fundraising pages and donate. They may also send emails to update
donors or to thank donors for their gifts.

APIs. We make certain application programming interfaces (“APIs”) available to
Clients. An API (in non-technical terms) allows a Client to automatically
retrieve certain information from our Sites, for use/display elsewhere (e.g., on
the Client’s website). To give an example, a Client might use our API to
retrieve the names and photos of the top five fundraisers for a Campaign; the
Client could then display that information on a leaderboard on its own website.
If you are fundraising for a Client, your name, picture, amount raised, and goal
can be retrieved by the Client through our API. If you create a team fundraising
page, then your name, the team goal, and the amount raised by the team can also
be retrieved by the Client through our API. If you host an event for a Client,
then your name, contact info, and the location of your event can be retrieved by
the benefitting Client through our API. If you are a Consumer who donates to a
Campaign, the Client who receives your donation may display your information,
such as name, photo (as provided by you), and amount to the Client’s own
donation appreciation wall or similar acknowledgment (which would be hosted
outside of Classy’s Services). The foregoing examples are for illustrative
purposes only. The Client with whom you engage has access to other information
through our API such as tickets sold and number of attendees.

Service Providers. We may disclose the information we collect from you to
vendors, service providers, contractors, or agents who perform functions on our
behalf. For example, these providers may help us administer our Sites and
Applications, manage and administer Campaigns, process credit card or other
payments, de-duplicate data, verify identities for fraud prevention purposes, or
provide analytics services by evaluating your use of the Sites. These vendors
have agreed to maintain the confidentiality, security, and integrity of your
information and may be located wherever the Sites or Services are available.
Where required by law, these companies agree to only use such information for
the purposes for which they have been engaged by us unless you expressly permit
them to use your information for other purposes. We now require vendors to whom
we disclose Personal Data (as defined below) and who are not subject to laws
based on the European Union General Data Protection Regulation to enter into
Data Protection Addendums containing, among other things, the Standard
Contractual Clauses, as promulgated by the European Commission in order to
provide protection for the Personal Data. If the other party does not comply
with its privacy obligations, Classy will take commercially reasonable steps to
prevent or stop the use or disclosure of Personal Data. For purposes of this
Policy, “Personal Data” means information that (i) is transferred from the EU to
the United States, (ii) is recorded in any form, (iii) is about, or relates to,
an identified or identifiable consumer, customer, supplier or other individual,
and (iv) can be linked to that consumer, customer supplier, or other individual.

Other Non-Affiliated Third Parties. We may disclose the information that we
collect about you to non-affiliated third parties (with your consent, if consent
is required by law), such as promotional partners and others with whom we have
marketing or other relationships. An example would include a co-sponsored
webinar in which you sign up to attend. In that case, we would provide your
information to the co-sponsor. Those third parties may use your information for
marketing purposes, such as to market products and services that they believe
would be of interest to you. We also may combine the information that we collect
about you with other information that we obtain from third parties. This
information may help us to determine what advertisements to direct to you, to
place on our website, and where to advertise our Services. As discussed in the
advertising section below, you have the ability to opt-out of certain uses of
your information. You also have the ability to opt-in to receiving certain
information from us and non-affiliated third parties.

Supplemental Service Partners. By purchasing or registering for products or
services offered by third parties as a result of your interaction with the
Services or use of the Sites, electing to receive communications (such as
emails) or electing to participate in surveys, contests, sweepstakes, or other
programs offered or sponsored by third parties on the Site, you consent to our
providing your personal information to those third parties, and you agree that
we are not responsible or liable for any of their actions or omissions. When you
provide your information in this manner, it will be apparent that you are
providing it to another party. Those other parties may use your personal
information in accordance with their own privacy policies. You will need to
contact those third parties to instruct them directly regarding your preferences
for the use of your personal information by them. Additionally, you agree that
we will have the right to use and disclose all such information submitted by you
to such third parties in the same manner in which we have the right to use and
disclose all other information submitted by you directly to us.

Strategic Partners. Classy has integration relationships with third-party
companies and individuals (“Partners”). These relationships extend the
functionality of the Services and the Partner’s application or service
(“Integrated Service”) by allowing the Services and the Integrated Service to
exchange Consumer data among other things and to establish linked business
processes between the two. Consumers or Clients who pay Classy for use of the
Services and use an Integrated Service are considered customers of both Classy
and the Partner. Classy and the Partner may share Consumer or Client contact,
account, financial and billing information, and business data with respect to
their integrated business relationship with the Consumer or Client. The sharing
of this information allows Classy and the Partner to establish the identity of
the shared customer and, in some cases, determine referral fees owed. This
sharing may also allow the Partner to provide consolidated billing services to
the shared customer and allow for the enhanced functionality of the Integrated
Service. Those Partners may use your personal information in accordance with
their own privacy policies. You will need to contact those third parties to
instruct them directly regarding your preferences for the use of your personal
information by them. Additionally, you agree that we will have the right to use
and disclose all such information submitted by you to such third parties in the
same manner in which we have the right to use and disclose all other information
submitted by you directly to us.

Affiliate and Referral Partners. Classy has referral relationships with
affiliates and third-party companies and individuals (“Referral Partners”) who
refer customers to Classy. Classy and a Referral Partner may share certain
information with respect to a Consumer or Client that is referred by Classy or a
Referral Partner to allow Classy and the Referral Partner to establish the
identity of the shared Consumer or Client and determine referral fees owed. We
also may share your information for the following reasons:

 * Business Transfers. If we are acquired by or merged with another company, if
   substantially all of our assets are transferred to another company, or as
   part of a bankruptcy proceeding, we may transfer the information we have
   collected from you to the acquiring company. You acknowledge and agree that
   any successor to or acquirer of Classy will continue to have the right to use
   your information in accordance with the terms of this Policy.
 * In Response to Legal Process. We also may disclose the information we collect
   from you in order to comply with the law, a judicial proceeding, court order,
   or other legal process, such as in response to a subpoena.
 * To Protect Classy and Others. We also may disclose the information we collect
   from you where we believe it is necessary to investigate, prevent, or take
   action regarding illegal activities, suspected fraud, situations involving
   potential threats to the safety of any person, or violations of our Terms of
   Service or this Policy.
 * Aggregate and Anonymized Information. We may share aggregated or anonymized
   information about Clients and Consumers with third parties for marketing,
   advertising, research, or similar purposes. For example, if we display
   advertisements on behalf of another party, we may share aggregated,
   demographic information with that other party about the Consumers and/or
   Clients to whom we displayed the advertisements. In addition, we may publish
   long-form research reports and blog posts summarizing aggregated data
   describing behaviors of Clients and Consumers on our Sites, Applications, and
   Services. We may also publish datasets containing aggregated Client and/or
   Consumer data to support replication of the published research results.

Third Party Applications. Third party applications, such as Instagram, Facebook,
Twitter, Pinterest, or Google buttons, may be available on our Sites. The owners
or providers of those third party applications may collect personally
identifiable information from you. Their collection of information is bound by
their own information collection policies and practices. Your interactions with
third party applications on our Sites may be shared with others within your
social network. We are not responsible for the collection and use of your
information by such third parties. You should review your privacy settings with
these third party applications to be sure you are only sharing information you
wish to share.

Our Sites include social media features, such as the Facebook “Like” button and
widgets such as the “share this button” or interactive mini-programs. These
features may collect your IP address, which page you are visiting on our Site,
and may set a cookie to enable the feature to function properly. Social media
features and widgets are either hosted by a third party or hosted directly on
our Site. Your interactions with these features are governed by the privacy
policy of the company providing such feature.

Network Advertisers. Network advertisers are third parties that display
advertisements based on your visits to our Sites and other websites you have
visited. This enables us and these third parties to target advertisements to you
for products and services in which you might be interested. These third party
services may use cookies, JavaScript, web beacons (including clear GIFs), and
other technologies to measure the effectiveness of their ads and to personalize
advertising content to you. These third party technologies are governed by each
third party’s specific privacy policy, not this one. We may provide these third
parties with information, including both personally identifiable and
non-personally identifiable information, about your usage of our Sites and our
Services. For more detailed information on the use of third party technologies
and how to opt out of receiving targeted advertisements, please see our cookie
policy here. If you would like to manage your consents to the cookies on our
sites, click here.

We use Local Storage, such as HTML5, to store content information and
preferences. Third parties with whom we partner to provide certain features on
our website or to display advertising based upon your web browsing activity may
also use HTML5 to collect and store information. Various browsers may offer
their own management tools for removing HTML5.

Third Party Links. At times, our Sites and Applications may contain links to
other third party websites. Any access to and use of such linked websites is not
governed by this Policy, but, is instead governed by the privacy policies of
those third party websites, and we are not responsible for the information
practices of such third party websites.

 


HOW SECURE IS INFORMATION ABOUT ME?

We have implemented and maintain appropriate technical and organizational
security measures, policies, and procedures designed to reduce the risk of
accidental destruction or loss, or unauthorized disclosure or access to such
information appropriate to the nature of the information, concerned, including,

 * where appropriate, password protection, encryption, tokenization, and secure
   socket layering to protect our Sites;
 * following strict security procedures in the storage and disclosure of your
   personal information to prevent unauthorized access to it; and
 * placing confidentiality requirements on our employees and vendors.

Please be aware that despite our best efforts, no data security measures can
guarantee 100% security all of the time. Please keep this in mind when
disclosing any of your personal information via the Internet.

As the security of personal information depends in part on the security of the
computer you use to communicate with us and the security you use to protect
usernames and passwords, you should take steps to protect against unauthorized
access to your password, computer, and web- enabled devices, among other things,
by signing off after using a shared computer, inserting a password on your
web-enabled device, choosing a password that nobody else knows or can easily
guess, keeping your password private, and periodically changing your password.
You should never share your login information with others. We are not
responsible for any lost, stolen, or compromised passwords, or for any activity
on your account via unauthorized password activity.

We endeavor to store your personal information for only as long as is reasonably
necessary for the purposes for which it was collected, as explained in this
Policy. Where your information is no longer needed, we will dispose of it in a
secure manner in accordance with our Data Retention Policy. In some
circumstances, we may store your personal information for longer periods of
time, for instance where we are required to do so in accordance with legal,
regulatory, tax, or accounting requirements.

In specific circumstances we may store your personal information for longer
periods of time so that we have an accurate record of your dealings with us in
the event of any complaints or challenges, or if we reasonably believe there is
a prospect of litigation relating to your personal information or dealings.

 


CAN I ACCESS AND MODIFY MY PERSONAL INFORMATION?

Upon request, Classy will provide you with information about whether we hold, or
process on behalf of another party, any of your personal information. To request
this information please email us at privacy@classy.org.

If your personal information changes, or if you no longer desire our service,
you may correct, update, delete/remove, or ask to have it removed from a public
forum or testimonial by making the change within your account settings or by
contacting us via one of the methods listed in this Policy. We will respond to
your request in accordance with applicable law. Please note that copies of
information that you have updated, modified, or deleted may continue to reside
in our systems for a period of time. Also, you may not be able to remove your
personal information from archived web pages that we no longer maintain, such as
information related to a Campaign in which you participated, where that
information is displayed by our Client or another party to whom the Client
provided your information. In the event we are unable to complete your access
request, we will let you know that we are unable to do so and why. We may
decline to process requests that are unreasonably repetitive, require
disproportionate technical effort, jeopardize the privacy of others, are
extremely impractical, or for which access is not otherwise required by local
law.

If your information has been shared or disclosed with another party, as
described above, or collected on behalf of a Client, then such party has
received their own copy of your data. If you have been contacted by one of these
parties, or one of our Clients, and wish to correct or request they delete your
information, please contact them directly.

 


WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?

Classy may send you emails from time to time, for example, to ask you about a
Campaign in which you participated. When you use our Services, you may have the
option of signing up for news and offers from us or other third parties, which
may include information about Campaigns, our newsletter, or other items that we
(or third parties) believe may be of interest to you. If, at any time, you would
like to stop receiving the information that you have requested to receive from
us, you may follow the opt-out instructions contained in any such email. Please
note that it may take up to 10 business days for us to process opt-out requests.

To opt out of products, programs, Services, or offers from our affiliates and
trusted partners, please contact privacy@classy.org or log into your account and
update your subscription preferences, where that functionality is made available
to you. If you opt out of receiving emails or promotions from us, we still may
send you emails about your account or any Services you have requested or
received from us, or for other customer services purposes, including sending you
receipts. In addition, you may still receive emails sent by our Clients through
means other than our system. Further, if you opt out of receiving information
related to a particular Campaign, you will still receive Classy communications
and communications from other organizations whose Campaigns you have
participated in or who have otherwise obtained your email address. As a result,
as a Consumer, you may have to unsubscribe from multiple emails before you stop
receiving all communications related to Campaigns in which you have participated
through our Services.

As a Client, by electing to stop receiving communications from us or through our
system you will no longer receive any updates on your account or on Campaigns in
which you are participating or have participated, including communications
regarding receipts and refunds. We do not recommend that you do this unless you
plan to no longer use the Services, have not participated in a Campaign for
which you need a receipt, are not currently participating in a Campaign, or are
not currently organizing a Campaign and will have no need to receive further
communications from us or through our system. If you are a Client, note that you
may not be able to unsubscribe from update communications about the Services
unless you close your account.

Even after you opt out of all communications, we will retain your information in
accordance with this Policy; however, we will no longer use it to contact you,
unless required by law or unless you later provide your information to us.
However, our Clients who have received your information in accordance with this
Policy may still use that information to contact you in accordance with their
own privacy policies, but they may not use our system to do so. If you would
like to delete your account with us, you may do so by emailing us at
support@classy.org and specifying which account(s) to delete.

 


INTERNATIONAL DATA TRANSFER

The Services are hosted in the United States and are governed by United States
law. If you are visiting the Sites or using the Services from outside the United
States, please be aware that your information may be transferred to, stored, and
processed in the United States where our servers and databases are located. The
data protection and other laws of the United States and other countries might
not be as comprehensive as those in your country.

By using the Sites and Services, you consent to your information being
transferred to our facilities and to the facilities of those third parties with
whom we share it as described in this Policy. We will take appropriate steps to
cause those transfers of personal information are in accordance with applicable
law, are carefully managed to protect your privacy rights and interests and
limited to countries which are recognized as providing an adequate level of
legal protection or where alternative adequate arrangements are in place to
protect your privacy rights.

In certain situations, Classy may be required to disclose personal data in
response to lawful requests by public authorities, including to meet national
security or law enforcement requirements.

IF YOU ARE LOCATED IN THE EUROPEAN ECONOMIC AREA (EEA), UNITED KINGDOM OR
SWITZERLAND

THIS SECTION ONLY APPLIES TO USERS OF OUR SERVICES THAT ARE LOCATED IN THE
EUROPEAN ECONOMIC AREA, UNITED KINGDOM OR SWITZERLAND AT THE TIME OF DATA
COLLECTION. WE MAY ASK YOU TO IDENTIFY WHICH COUNTRY YOU ARE LOCATED IN WHEN YOU
USE SOME OF OUR PRODUCTS OR SERVICES, OR WE MAY RELY ON YOUR IP ADDRESS TO
IDENTIFY YOUR COUNTRY LOCATION.

Classy processes Personal Data as a “processor,” “joint controller,” and as a
“controller” under the European Union’s General Data Protection Regulation. A
“controller” is an entity that determines the purposes for which and the manner
in which any personal information is processed. Any third parties that act as
our service providers are “data processors” that handle your personal
information in accordance with our instructions. With respect to your personal
data that you enter or that is received through our websites that is not
directly related to a Customer’s Campaign, Classy is the controller. To the
extent that Classy receives personal information from a Consumer through a
Customer’s Campaign, Classy and its Customer are joint data controllers. This
means that you may choose to exercise your rights, including as described below,
with Classy or the relevant Classy Customer. Please do not hesitate to contact
us if you are unsure who the relevant Classy Customer is for a given Campaign or
would like their contact information at support@classy.org. If you are in the
EEA, United Kingdom or Switzerland, you have the following rights (where
applicable):

 * Access: You have the right to request a copy of the information we are
   processing about you;
 * Rectification: You have the right to have incomplete or inaccurate
   information that we process about you rectified;
 * Deletion: You have the right to request that we delete information that we
   process about you, except we are not obliged to do so if we need to retain
   such data in order to comply with a legal obligation or to establish,
   exercise, or defend legal claims;
 * Restriction. You have the right to restrict our processing of your
   information where you believe such data to be inaccurate; our processing is
   unlawful; or that we no longer need to process such data for a particular
   purpose unless we are not able to delete the data due to a legal or other
   obligation or because you do not wish for us to delete it;
 * Portability. You have the right to obtain information we hold about you, in a
   structured, electronic format, and to transmit such data to another data
   controller, where this is (a) information which you have provided to us, and
   (b) if we are processing that data on the basis of your consent or to perform
   a contract with you;
 * Objection. Where the legal basis for processing your information is our
   legitimate interest, you have the right to object to such processing on
   grounds relating to your particular situation. We will abide by your request
   unless we have compelling legitimate grounds for the processing which
   override your interests, or if we need to continue to process the data for
   the establishment, exercise, or defense of a legal claim;
 * Withdrawing consent: If you have consented to our processing of your
   information, you have the right to withdraw your consent at any time, free of
   charge. This includes where you wish to opt out from marketing messages.

You can make a request to exercise any of these rights in relation to your
information by contacting us via the methods listed below under Contact Us. For
your own privacy and security, at our discretion, we may require you to prove
your identity before providing the requested information. We reserve the right
to charge a fee where permitted by law, for instance if your request is
manifestly unfounded or excessive. We may not always be able to fully address
your request, for example if it would impact the duty of confidentiality we owe
to others, or if we are legally entitled to deal with the request in a different
way.

You also have the right to lodge a complaint with the local data protection
authority if you believe that we have not complied with applicable data
protection laws. A list of local data protection authorities in European
countries is available here.

Our legal basis for collecting and using the personal information described
above will depend on the personal information concerned and the specific context
in which we collect it. However, we will normally collect personal information
from you only where we have your consent to do so, where we need the personal
information to perform a contract with you, or where the processing is in our
legitimate interests and not overridden by your data protection interests or
fundamental rights and freedoms. In some cases, we may also have a legal
obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement
or to perform a contract with you, we will make this clear at the relevant time
and advise you whether the provision of your personal information is mandatory
or not (as well as of the possible consequences if you do not provide your
personal information). Similarly, if we collect and use your personal
information in reliance on our legitimate interests (or those of any other
party), we will make clear to you at the relevant time what those legitimate
interests are.

 


CHILDREN UNDER 13 (OR 16 IN THE EU)

Our Sites are for general audiences, and we do not knowingly market to, or
solicit information, accept service or collect information from or about
children or sell products to children under the age of 13 (or 16 in the EU). If
you are under the age of 13 (or 16 in the EU), you must ask your parent or
guardian to use our Sites directly, on your behalf. Furthermore, we may restrict
entries to any contests, sweepstakes, or promotions to those who are at least 18
years of age. If we become aware that any person submitting information to the
Sites is under the age of 13 (or 16 in the EU), we will attempt to delete the
account and any related information as soon as possible. By using the Sites, you
hereby represent that you are at least 13 years old (or 16 in the EU).

 


TERMS OF SERVICE

Your use our Sites or Services, as well as any dispute over privacy, are subject
to this Policy and our Terms of Service, https://www.classy.org/terms/,
including applicable limitations on damages and the resolution of disputes.

 


SPECIAL INFORMATION FOR CALIFORNIA RESIDENTS

California Consumer Privacy Act Rights. Under the California Consumer Privacy
Act of 2018 (as amended by the California Privacy Rights Act (“CPRA”) and
collectively referred to as, “CCPA”) California residents have certain rights
regarding their personally identifiable information. If you would like to
exercise these rights, please contact us using the email address, toll free
phone number, or mailing address listed within the Contact Us section below. For
your own privacy and security, at our discretion, we may require you to prove
your identity before providing the requested information. It may take us some
time to respond to your request, but we will do so within the requirements of
the CCPA. This Policy provides you disclosure regarding the personal information
we collect from you and the purposes for doing so. This section of the Policy
supplements our other privacy policies and notices. In the event of a conflict
between any other policy, statement, or notice and this portion of our Policy,
this portion of our Policy will prevail as to California consumers and their
rights under California privacy law.

As used in this Special Information for California Residents section of the
Policy, the term “personal information” means information that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with you. Personal information
does not include information that is publicly available, de-identified, or
aggregated.

Please see WHAT INFORMATION DO WE COLLECT ABOUT YOU AND WHY? for the categories
of personal information we may collect.

 * We do not “sell” your personal information as provided under the CCPA.
   However, we may “share” your personal information under the definition
   provided in the CPRA based on processing your data for targeted advertising
   as further described in our cookie policy here.
 * Right to request disclosure as to personal information Classy has collected
   about you:
   * Upon a verifiable request, made through one of the methods provided within
     the Contact Us section below, we will disclose to you the items listed
     below, one or more of which may be provided by reference to this Policy:
   * The categories of personal information it has collected about the you.
   * The categories of sources from which the personal information was
     collected.
   * The business purpose behind collecting the personal information.
   * The categories of third parties with whom Classy has shared the
     information.
   * The specific pieces of personal information Classy has collected about you.
 * Right to request deletion: upon a verifiable request, made through one of the
   methods provided within the Contact Us section below, we will delete personal
   information we have regarding you and direct our vendors to delete your
   personal information from their records, to the extent provided by the CCPA.
 * Right to be free from discrimination: Classy will not discriminate against
   you for exercising any of your rights under the CCPA. Please keep in mind
   that under certain circumstances, we may charge you a different price or
   rate, or provide a different level or quality of goods or services, if that
   difference is reasonably related to the value provided to you by your
   personal information.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep the categories of personal information described above for as long as is
necessary for the purposes described in this section or as otherwise authorized
or permitted by law. This generally means holding the information for as long as
one of the following apply:

 * The personal information is reasonably necessary to manage our operations, to
   manage your relationship with us, or to satisfy another purpose for which we
   collected the information;
 * The personal information is reasonably necessary to carry out a disclosed
   purpose that is reasonably compatible with the context in which the personal
   information was collected;
 * The personal information is reasonably required to protect or defend our
   rights or property; or
 * We are otherwise required or permitted to keep your information by applicable
   laws or regulations.

Where information is used for more than one purpose, we will retain it until the
purpose with the latest period expires.

 


SPECIAL INFORMATION FOR VIRGINIA RESIDENTS

This section of our Policy (“Virginia Notice”) is provided pursuant to the
Virginia Consumer Data Protection Act (“VCDPA”) and describes how we process
Personal Data of Virginia consumers. In the event of a conflict between any
other section of this Policy, other policy, statement, or notice and this
Virginia Notice, this Virginia Notice will prevail as to Virginia consumers and
their rights under Virginia privacy law.

As used in this Virginia Notice, the term “Personal Data” means information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with you. Personal
Data does not include information that is publicly available, de-identified, or
aggregated.

A. COLLECTION OF PERSONAL DATA

When you use our Services, we may collect your name, email address, login
details, phone number, zip code, country, and payment card information. We may
also passively collect certain data when you interact with the Services such as
your IP address and the type of Internet browser or mobile device.

We may process your Personal Data for targeted advertising. To opt out, please
click here.

For more information on the categories of Personal Data that we collect and the
purpose for processing such Personal Data, please visit the “WHAT INFORMATION DO
WE COLLECT ABOUT YOU AND WHY?” section of this Policy.

B. DISCLOSURE OF PERSONAL DATA

We may disclose certain Personal Data described above among our affiliates and
subsidiaries and with our agents, consultants and vendors. We may also disclose
Personal Data with certain third parties such as social networking services that
partner with us.

For more information on the categories of third parties that we disclose
Personal Data, please visit the “WHAT INFORMATION DO WE COLLECT ABOUT YOU AND
WHY?” section of this Policy.

C. RIGHTS UNDER THE VCDPA

If you are a Virginia resident, you have the following rights: to request access
to certain Personal Data, correction of inaccuracies in Personal Data, and
deletion of Personal Data, subject to certain exceptions. You will not be
discriminated against because you exercised any of your rights under the VCDPA.

You also have the right to opt-out of Classy using your information for targeted
advertising. To opt out of the use of your information for these purposes,
please click here.

We may be unable to process your privacy rights request related to your Personal
Data. If you are a resident of Virginia whose privacy rights request has
previously been denied by us and you believe we denied it in error, you may
appeal for reconsideration of your request by contacting us through one of the
methods provided within the Contact Us section below.

In order to protect your privacy and security, we will authenticate your
identity prior to responding to your request, by asking for information such as
your name, email, and/or information already maintained by Classy about you or
additional proof where necessary.

 


CHANGES TO THIS POLICY

We may change this Policy from time to time, so be sure to check back
periodically. If we make any changes to this Policy that materially affect our
practices with regard to the personal information we have previously collected
from you, we will endeavor to notify you in advance of such change, by
highlighting the change on the Sites or by sending an email to you at the email
address that you have registered with us. Your continued use of the Services
after any changes or revisions to this Policy will indicate your agreement with
the terms of the revised Policy.

 


CONTACT US

Classy regularly reviews its practices regarding personally identifiable
information and this Policy. If you have any questions, comments or concerns,
please contact us at:

Attn: Classy Privacy
Classy, Inc.
PO BOX 121270
SAN DIEGO, CA 92112
Phone: (619) 961-1892
Email: privacy@classy.org



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