Date of Last Revision: 1 February 2020.
In the context of our Services, before you use or submit any information through or in connection with the Services, please review this Policy carefully. By using any part of the Services, you consent to the collection, use, and disclosure of your information as outlined in this Policy. To the extent allowed by law, the English version of this Policy is binding and other translations are for convenience only.
If you are in the European Economic Area, the United Kingdom or Switzerland:
If you are a resident of California, the California Consumer Privacy Act of 2018 provides you with additional rights. Please see the California Consumer Privacy Act Notice for more information.
Information We Collect
As further described below, when you use or otherwise access the Services, we collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from your browser or device (e.g. by logging how you interact with our Services).
When you register for our Services or open an account, we collect your contact and log in details, your zip/post code, your country and any information you choose to provide us with (such as a profile picture).
If you are a charity and you establish an account with the GFM Charity Platform, we will collect the name, tax ID, physical address, email address, date of birth and phone number of the person who establishes a charity account and claims your charity (the "Charity Contact") and any other information that is provided to us by GuideStar about your charity. We may also collect, if the Charity Contact chooses to provide it, the Charity Contact’s gender or any photos uploaded to the Site. You can edit your information by logging in to your account and making changes at any time. If you have any questions about, or wish to review or correct the information we maintain about you, you may send an email to email@example.com.
When you create a campaign on either Platform, we collect the information you choose to provide us with in relation to your campaign. For example, you can provide a campaign title, choose a campaign category, upload images and describe your campaign goal(s).
Our payment processors collect and retain information related to your withdrawal of funds from any campaign.
On the ST-IF Platform, when you donate to a fundraising campaign, we collect your contact details (such as name and email address), zip or post code, country and any other information you choose to provide us with (such as a description of why you have donated). If you make a donation on the GFM Charity Platform, in addition to the above, we will also collect your address.
Our payment processors collect your credit card details and other information needed in order to process the donation.
You can post comments, leave feedback, send thank-you notes and communicate with other users through our Platform. All content, including any comments, feedback and notes that you choose to post through our Platform are made available to the public by default. You can also get in touch with us via a contact form, email or by other means; for example, with questions about our Services, for customer support or to let us know your ideas for new products or modifications to existing products. When you do so, we collect the information you choose to provide us with, such as your contact details, any images you choose to upload and the contents and nature of your message.
Please remember that any information that is disclosed in these areas becomes public information for both us and other users to use and share. Please be considerate and respectful of others while using the community to share your opinions. We reserve the right, but do not have the obligation, to review and monitor such posting or any other content on our Services, and to remove postings or content that may be viewed as inappropriate or offensive to others.
You can choose to provide us with information relating to third parties. For example, if you choose to share your campaign on the Platform with family and friends, we request access to information stored in your email and mobile device address books, such as names, email addresses or phone numbers of your contacts (collectively, "Third-Party Data").
If you use any feature of the Services that allows you to communicate with third parties (such as to refer a third party to the Services or to communicate with them regarding a campaign or a donation), either by submitting Third-Party Data to the Services or otherwise permitting the Services to automatically access Third-Party Data in your possession, you acknowledge and agree that you have the authority of the relevant third party for us to access and use the relevant Third-Party Data and that you have notified these third parties and informed them how their information is collected and used by ST-IF 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. We use Third-Party Data to (1) contact such third party using the Third-Party Data provided, and/or (2) provide you with an editable template message designed to facilitate communication between you and such third party through the Services. In addition to sending the foregoing communications, we may also send reminders or related messages to you and to third parties on your behalf from time to time where permitted by applicable law. In each case, any such communications sent to third parties using Third-Party Data will provide a means to "opt out" of receiving further communications of a similar nature.
You can also provide us with information about yourself or third parties that is considered sensitive, such as political opinions, health-related information or religious beliefs. When you provide such information to us directly, we may seek your consent, where appropriate, to process this information, unless you choose to provide such information to be published publicly in relation to your campaign or donation or otherwise.
We collect the information listed in this section for the purposes described below in the section "Our Use of Information Collected". While you are under no obligation to provide us with such information, should you choose to withhold such information, we may not be able to provide you with some or all of the Services.
On the GFM Charity Platform, ST-IF may enable a charity to run a promotion, like a sweepstake, or set up an event. If you enter a sweepstake, we collect your name, address and contact information so that the charity or other entity associated with the sweepstake may administer the competition and award prizes and, to the extent permitted by law, provide you with information on upcoming events, announcements and other promotions. Likewise, if you register for an event, we collect your information for the purposes of that event.
When you interact with ST-IF through the Services, we automatically receive and store certain information from devices that you use to access the Services. 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 accessed the Services, your operating system and location data through an IP address that identifies the city and state where you logged into the Platform or your precise geo-location if you have permitted your mobile device to provide that information to us. ST-IF either stores such information itself or such information is included in databases owned and maintained by ST-IF or its agents or service providers.
In an ongoing effort to better understand the use of our Services and serve you, ST-IF often conducts research on its customer demographics, interests and behaviour based on information that we collect. We can anonymise and aggregate the information collected through the Services for research purposes or any other purposes, and we can share this information with our affiliates, agents, business partners or other third parties (e.g. Google Analytics).
When you use the Services to organise a fundraising campaign, the Services request that you provide your city or town, and state or province or county etc of residence. Please bear in mind that other users of the Services can view your city or town and state or province of residence in connection with the campaign if it is made available within ST-IF's Public Search Directory. We also use your location information as described above under "Device & Usage Information", and in an aggregate way, as described above in the "Aggregated Data" section.
When you interact with the Services, we try to make that experience simple and meaningful. When you visit our Platform, our web server sends a cookie to your computer or mobile device. Cookies are small pieces of information that are issued to your computer or mobile device when you visit a website or access or use a mobile application, and that store and sometimes track information about your use of the Platform.
Some cookies are strictly necessary to make our Services available to you ("Functional cookies"). For example, to provide the chat and log in functionalities and to remember your consent and privacy choices. We cannot provide our Services without Functional cookies.
We also work with third-party advertising companies to show you ads we think may be of interest to you and to track sales from ads for our Services. For example, we may show you ads about our products and services on third-party websites and apps, or ads about third parties’ products and services on our website and app. To do so, we and our advertising partners place and access cookies through our Services and otherwise collect or access Personal Information collected over time and across different online services. For example, we use Google Analytics Advertising Features, such as Google AdWords and Double Click. You can opt out of the Google Analytics Advertising Features via https://tools.google.com/dlpage/gaoptout/.
Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser settings to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browsers or mobile devices.
You can also consult the "Help" section of your browser for more information (e.g. Internet Explorer; Google Chrome; Mozilla Firefox or Apple Safari). You can also manage the use of Flash technologies, including cookies and local storage objects, with the Flash management tools available on Adobe's website. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
Web beacons: A web beacon is a transparent image file. Web beacons enable the Platform to track website usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer. We may use them in association with cookies to understand how visitors interact with the pages and the content on the pages of the Platform. We may also use web beacons to track whether you have opened an HTML email. When the email is opened, a part of the code that makes up the HTML page calls a web server to load the web beacon which then generates a record showing that the email has been viewed. Web beacons may also recognise when the email was opened, how many times it was forwarded and which URLs (links within the email) were clicked.
Pixel Tags: In addition, we may use pixel tags (also referred to as clear gifs or web bugs). Pixel tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of our users. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly in web pages. Pixel tags also allow us to send email messages in a format users can read, and they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by pixel tags to information that is intended to identify our users.
One of the special features of the Services is that it allows you to enable or log in to the Services via various social networking services like Facebook or Twitter ("Social Networking Service(s)"). By directly integrating these services, we aim to make your online experiences richer and more personalised. To take advantage of this feature, we will ask you to provide your user details 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 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 (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 Policy. 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 ST-IF 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.
ST-IF uses the information collected from the Services in a manner that is consistent with this Policy. We use the information that you provide (or otherwise permit the Services to access) for the following purposes:
We use the information we collect to contact you for administrative purposes (e.g. to provide services and information that you request or to respond to comments and questions). For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem.
We also use the information we collect to send you communications relating to the Services, such as updates on promotions and events, communications relating to products and services offered by us and by third parties, and communications about services we believe will be of interest to you. For example, we can send periodic emails to registered users of the Services relating to their recent interactions with the Services, such as donating to a campaign or "hearting" a campaign.
We use the information we collect to operate, maintain and provide our Services such as enabling access to the Platform, customer support or to complete transactions. Also, as part of the GFM Charity Service unique to the GFM Charity Platform, we may provide (i) a report to campaign or event organisers that tells them who responded to a particular offer or to facilitate the fulfilment of an order that you have made; or (ii) our gift registry partners with all the necessary data to accurately update their gift registries, including data related to the establishment of a donation registry and the applicable charities, campaigns on the GFM Charity Platform that established the donation registry.
We use the information we collect to analyse data usage trends and preferences in order to improve the accuracy, effectiveness, security, usability or popularity of our Services.
If you are located in Europe, we process information as listed under A, B and C as necessary (i) to fulfil our obligations under our contract with you or in order to take steps at your request prior to entering into a contract, or (ii) for our legitimate interest, such as to maintain our relationship with you or to protect you and us against fraud.
We use the information we collect, such as device identifiers, to learn how users interact with our Services in order to personalise the content of our Services, such as customising the language and campaigns on our home page based on your location.
If you are located in Europe, we process information as listed under D as necessary for our legitimate interest.
We use the information that we collect to defend our legal rights, comply with state, local, federal or international laws and enforce our Terms of Service and this Policy.
If you are located in Europe, we process information as listed under E to fulfil our obligations under our contract with you or in order to take steps at your request prior to entering into a contract; (i) for our legitimate interest to maintain our relationship with you, (ii) to protect our business or protect you and us against fraud; or (iii) to comply with legal obligations.
Our Disclosure of Information Collected Through the Services
There are certain circumstances in which we share information collected through the Services with certain third parties without further notice to you, as set forth below.
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 transferred assets.
ST-IF can access, disclose, transfer and retain your information when we have a good faith belief that doing so is necessary to: (i) comply with the law including with subpoenas, search warrants, court orders, and other legal process; and respond to enquiries or requests from government, regulatory, law enforcement, public authorities, or content protection organisations; (ii) protect and defend the legal rights, privacy, safety or property of ST-IF, its affiliates, subsidiaries, employees, agents, contractors or its users; (iii) permit us to pursue available remedies, commence, participate in or defend litigation, or limit the damages we may sustain; or (iv) enforce this Policy or any applicable Terms of Service.
We share your information with campaign organisers and, if they are not one and the same, the beneficiaries of the campaign. For example, if you donate to a fundraising campaign for a charity and we share your name, email address and other details you’ve provided in connection with your donation with the campaign organiser or beneficiary, they may then contact you. For example, if an individual starts a campaign for a charity and you donate to that campaign, the campaign organiser (individual) and the beneficiary (charity) will receive your information. On the ST-IF Platform, the information is provided if requested. On the GFM Charity Platform, the information is accessible to the charity through the GFM Charity Platform records centre. In the same scenario, beneficiary may communicate with you about your donation and/or may rely on your information in order to comply with its legal and auditing requirements.
We may share your information in the event that you consent to the sharing of your information. For example, we may partner with third party organisations to arrange for specific campaigns. If you consent to us delivering your contact information to a specific partner, we share your name, email address and other details you’ve provided in connection with your donation to the specific campaign with the partner organisation.
We aggregate and/or anonymise your details so that the information no longer refers to you individually. We may use and disclose aggregate and anonymised data for any lawful purpose.
We provide other users of our Services with your information if you choose to make your information publicly available in a publicly accessible area of the Services, such as in your campaign or in the comments.
Please be advised that some information that you provide may be publicly accessible, such as information posted in forums or comment sections. We also collect information through customer support communications, your communication to us of ideas for new products or modifications to existing products, feedback and other unsolicited submissions (collectively, with publicly-accessible information, "Unsolicited Information"). By sending us Unsolicited Information, you further: (a) agree that we are under no obligation of confidentiality, express or implied, with respect to the Unsolicited Information, (b) acknowledge that we may have something similar to the Unsolicited Information already under consideration or in development, (c) grant us an irrevocable, non-exclusive, royalty-free, perpetual, worldwide licence to use, modify, prepare derivative works, publish, distribute and sub-license the Unsolicited Information, and (d) irrevocably waive, and cause to be waived, against ST-IF and its users any claims and assertions of any moral rights contained in such Unsolicited Information. This Unsolicited Information section shall survive any termination of your account or the Services.
Our Services are not designed for use by individuals under the age of 13 (or 16 for children located in Europe). If you are under the age of 13 (or 16 for children located in Europe), 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 Europe) has provided personal information to ST-IF through the Services, please contact us at firstname.lastname@example.org and we will delete that information from our databases to the extent required by law.
ST-IF has implemented technical and organisational security measures to protect the information provided via the Services from loss, misuse and unauthorised access, disclosure, alteration or destruction. For example, ST-IF limits access to information only to employees and authorised service providers who need to know such information for the purposes described in this Policy. However, no Internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information to ST-IF via the Internet.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
Retention of your information
We will only retain the information for as long as necessary for the purpose for which that information was collected and to the extent permitted or required by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take step to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies.
Access to Information
When determining the retention period, we take into account various criteria, such as the type of products and services requested by you or that you are provided with by us, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide you with if we delete some information about you, mandatory retention periods provided by law and the statute of limitations.
Your Rights and Choices
You can access and correct certain personal details. Go to the "Account Settings" section of our Platform. You can control whether certain information you post to the Services is publicly available to others by adjusting the settings in your account. You can also request in writing copies of personal information about you held by us. If that information is inaccurate, please let us know and we will endeavour to make the necessary amendments, and/or delete or block the relevant information according to your request. For more information about your rights if you are in Europe, please see the "Users in Europe" section below.
Users from outside the United States
Users in Europe
If you are located in Europe, you have the right to ask for an overview of the information we process about you and for a copy of your information. In addition, you may request that we update and correct inaccuracies, delete your information, restrict processing of your information, or exercise your right to data portability to easily transfer your information to another company. In some cases, you may object to the processing of your information, and whenever we ask for and obtain your consent to process your information, you can withdraw it at any time. The withdrawal of consent shall not affect the lawfulness of the processing based on consent before its withdrawal. The above rights may be limited under applicable law.
Your access to and use of the Services is subject to the Terms of Service, which may be made available to you in connection with your use of the Services.
Changes to ST-IF's Privacy Notice
ST-IF reserves the right to update or modify this Policy periodically and at any time. We will notify you of any updates or changes we make to this Policy. If you disagree with our revisions to the Policy, you can deactivate your account or discontinue the use of our Services. Please review this Policy periodically, for any updates or changes to this Policy.
If you are in Europe, you will not be required to agree to changes to this Privacy Notice, unless we specifically seek your consent.
Please also feel free to contact us if you have any questions about ST-IF's Privacy Notice or the information practices of the Services.
You can contact us as follows:
196 High Road, N228HH, London, UK