Privacy Policy

#MILLSUMMIT 2022
Effective Date: March 4, 2020

This Privacy Policy (“Policy”) describes how Spur Impact Association (“Spur Impact,” “we,” “our” or “us”), through the Delaware Gives Platform at degives.org and any other websites operated by Spur Impact using the Delaware Gives Platform that link to this Policy (together, the “Platform”), may collect, use and disclose the personal information we collect from you or about you in the context of your relationship with us; the choices you have regarding our use of your personal information; and how to contact us regarding our privacy practices. 

Before engaging with us or submitting personal information to us or using the Platform, please review this Policy carefully. 
 
Information We Collect

When you use or otherwise access the Platform, we collect personal information in multiple ways, including when you provide information directly to us, when we collect information from your browser or device and when we receive personal information about you from others. 

Information You Provide

We may collect the following personal information that you provide directly to us:

Account Information.  When you register for a Delaware Gives account, we collect your name, email address, physical address, phone number, demographic information, username and password. If you are a nonprofit organization and you establish a Delaware Gives account, we will collect the name, physical address, email address and phone number of the person who establishes the organization’s account. We may also collect other information relevant to confirming the tax status of the organization. 

Fundraising Campaign Information.  When you create a fundraising campaign on the Platform, we collect the information you choose to provide us in relation to your campaign such as your fundraising goal, any commentary about the nonprofit organization or campaign and any photos you post. 

Donation Information.  When you donate to a fundraising campaign, we collect your name, email address, physical address, age and any information you choose to provide us. 
 
Communication Information. If you contact us via our contact form or by email, or chat with us on our chatbot, we collect the information you choose to provide us such as your name, email address and the content of your message. 
 
Sweepstakes/Promotion/Event Information. If you enter a sweepstakes or promotion, we collect your name and contact information so that the entity associated with the sweepstakes or promotion may administer the sweepstakes or promotion and fulfill prizes. If you register for an event, we will collect your personal information for the purposes of the event. We may also collect your name and email address to provide you with information on upcoming events, announcements and promotions. 
 
Information Collected Automatically

We may automatically collect certain information about you when you access or use the Platform. The methods that may be used on the Platform to automatically collect information include: 
 
·       Log Information: Log information is data about your use of the Platform that may be stored in log files. 

  • Collected by Cookies and Other Tracking Technologies: Cookies, web beacons and other tracking technologies (“tracking technologies”) may be used to collect information about your interactions with the Platform. Brief descriptions of common tracking technologies are provided below. 
    • Cookies - A cookie is a small text file that is stored on a user’s device. Session cookies make it easier for you to navigate the Platform and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Platform, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Platform may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. The Platform may associate some or all of these types of cookies with your device(s). Please see “Your Choices” below for information on your choices related to tracking technologies.   
    • Web Beacons - Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages. Web beacons (unlike cookies) are not placed on your computer. Web beacons may be used, without limitation, to count the number of visitors to the Platform and to monitor how users navigate the Platform. 
    • Pixel Tags - 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. 

Information Collected from Third Parties

We may collect personal information about you from other sources. This personal information may include, for example, personal information about you that another individual included in a fundraising campaign.  
 
How We Use Your Personal Information

We may use your personal information to:

·       Provide you the services on the Platform;
·       Communicate with you;
·       Improve the Platform and our offerings; 
·       Maintain the security of the Platform; and
·       Comply with our legal obligations and respond to legal proceedings.  

Provide You the Services on the Platform: We use your personal information to enable access to the Platform, provide customer support or to complete a transaction.  We also use your personal information to provide you with a tax acknowledgment when you make a donation. Additionally, we also may include your personal information in a report to campaign organizers and/or nonprofit organizations that are beneficiaries of fundraising campaigns about donors to the campaign. 

Communicate with you: We may use your personal information to contact you for administrative purposes (e.g., to provide services and information that you request or to respond to comments and questions). We may also send you communications about promotions, events or updates to the Platform. For example, we may send periodic emails to registered users of the Platform relating to their recent interactions with the Platform or about upcoming fundraising campaigns. 

Improve the Platform and our Offerings: In order to improve your experience and provide you with the services that you are interested in, we may use your personal information to understand who is accessing the Platform, analyze how the Platform is being accessed and used, improve the functionality of the Platform and develop new offerings through the Platform. 

Maintain the Security of the Platform: To maintain the security and integrity of the Platform, we use your personal information to detect security incidents and protect the Platform against fraudulent and illegal activity. 

Comply with Our Legal Obligations and Respond to Legal Proceedings: We use your personal information to comply with our legal obligations. We may also use your personal information to establish, exercise or defend legal claims and enforce our terms of use.  
 
How We Share Your Personal Information 
 
We may share your personal information in the following circumstances:

·       Your consent. We will share your personal information if you consent or direct us to share your personal information. 
·       Vendors. We may share your personal information with vendors who perform certain business tasks on our behalf, such as email marketing, payment processing, data storage and security and fraud prevention. We limit the personal information provided to these vendors to that which is reasonably necessary for them to perform their functions. 
·       Campaign Organizers and Beneficiaries of Campaigns. If you donate to a campaign, we will share your information with the campaign organizer and/or the nonprofit organization that is the beneficiary of the campaign, if applicable. For example, if you donate to a fundraising campaign for a nonprofit organization, we will share your name, email address and other information that you have provided through the Platform with the nonprofit organization, who may contact you, including to send you promotional emails. 
·       Sweepstakes and Promotions. We will share your personal information if you enter into a sweepstakes or register for an event through the Platform. In such instances, we will share your information with the people who are running the sweepstakes or conducting the event.
·       Legal. We may share your personal information if we have a good faith belief that such disclosure is necessary. For example, we may share your personal information:
o   to comply with relevant laws or to respond to a subpoena, warrant or court order served on us;
o   to respond to valid requests by government agencies, including law enforcement authorities;
o   if we believe your actions are inconsistent with our terms of use, user agreements, applicable terms or policies; 
o   to protect against fraud and for risk management purposes;
o   to protect the rights, property, life, health, security or safety of Spur Impact, the Platform, its employees, donors campaigners and any third party; or
o   for the establishment of defenses or claims in any legal action or dispute involving Spur Impact or any of its officers, directors, employees, agents, contractors and partners.

·       Sale of Business or Assets. In the event we sell, transfer or assign all or a portion of our business or assets (e.g., further to a sale, merger, consolidation, change of control, reorganization, liquidation or any other business transaction, including diligence and negotiation of such transactions), we reserve the right to disclose any information we collect through the Platform. You acknowledge that such transfers may occur and are permitted by and subject to this Policy. 
 
Analytics 
 
We use analytics services, such as Google Analytics, which uses cookies and other tracking technologies to collect information to analyze your use of the Platform. The information collected by the tracking technologies about your interactions with the Platform is used to assess how often you visit the Platform and what other websites you visited before coming to the Platform. For more information on Google’s privacy practices for Google Analytics, please visit https://support.google.com/analytics/answer/6004245. You may prevent Google Analytics from recognizing you on the Platform by deleting or disabling cookies from the Platform. For more information, see “Your Choices” below.
 
Social Features and Advertising 
 
Certain functionalities on our Platform may permit interactions that you initiate between the Platform and third-party services, such as social networks (“Social Features”).  Examples of Social Features include features enabling you to “like” or “share” our content. If you use Social Features, and potentially other third-party services, information you post or provide access to may be publicly displayed by the third-party service you use. Also, both Spur Impact and the third party may have access to certain information about you and your use of the Platform and the third-party service.

We may engage and work with vendors and other third parties to serve advertisements on the Platform and/or on third-party services. Some of these ads may be tailored to your interest based on your use of the Platform and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising,” which may include sending you an ad on a third-party service after you have left the Platform. We and our advertising partners place and access tracking technologies through our Platform and otherwise collect or access information collected over time and across different online services. For additional information about these tracking technologies, please see “Personal Information We Collect‒Information Collected Automatically.”  
 
Your Choices
 
Unsubscribe from Emails

If you no longer wish to receive promotional emails, you may unsubscribe at any time by clicking the “unsubscribe” link in the promotional emails sent to you or by contacting us using the information below under “Contact Us.” Please note that even if you opt-out of receiving promotional emails from us, we may continue to send you non-promotional emails. 

Your Account

If you have an account with us, you may make changes to your personal information by logging in to your account and making changes there. You may also delete your account. Please note, however, you will not be able to delete any fundraising campaign pages you created if donations were received for such campaign. 

Opt-Out of Tracking Technologies

Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options,” “tools” or “preferences” menu. You may also consult the browser’s “help” menu. You can learn more about cookies and how to block cookies on different types of browsers by visiting http://www.allaboutcookies.org. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies or other tracking technologies. For information on disabling Flash cookies, visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html. Please be aware that if you disable or remove these technologies, some parts of our Platform may not work and when you revisit the Platform your ability to limit browser-based tracking technologies is subject to your browser settings and limitations. 

Your browser settings may also allow you to transmit a “Do Not Track” signal, which is a privacy preference, when you visit various websites. Like many websites, the Platform is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you may wish to visit https://allaboutdnt.com/.  

Opt-Out of Analytics

You may exercise choices regarding the use of cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptout

Opt-Out of Interest-Based Advertising

You can generally opt-out of receiving targeted ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) by visiting http://optout.networkadvertising.org/. You may also opt-out of receiving targeted advertisements from other companies that perform interest-based advertising services via the Digital Advertising Alliance (DAA) site at http://optout.aboutads.info/. Please note that when using the ad industry opt-out tools described above you may need to execute opt-outs for each browser or device that you use. Opting out of interest-based advertising does not mean you will no longer see advertising online but it does mean that the companies from which you opt-out will no longer show ads that have been tailored to your interests. 
 
Third Parties
 
This Policy applies only to our Platform. The Platform and other materials may contain references and/or links to third-party websites and services, including links to nonprofit organizations that are running fundraising campaigns on the Platform. We are not responsible for any third party’s data collection or privacy practices, and we have no control over what information third parties track or collect. Any access to and use of such linked websites is not governed by this Policy but instead is governed by the privacy policies of those third-party websites. We encourage you to review the privacy policies posted on those third-party websites for further information. 
 
Security 
 
We maintain technical and organizational measures to protect your personal information against loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and we cannot guarantee the security of your personal information collected through the Platform. You should take special care in deciding what information you send to us via email.
 
Children’s Privacy
 
Our Platform is not intended for use by individuals under the age of 13. If you are under the age of 13, please do not use the Platform. If you have reason to believe that a child under the age of 13 has provided personal information to Spur Impact through the Platform, please contact [email protected] and we will delete that information to the extent required by law.
 
International Users
 
If you are visiting the Platform from outside the United States, please be aware that Spur Impact is based in the United States and the information we collect will be transferred to, processed and stored on our servers in the United States in accordance with this Policy and applicable laws. The data protection laws and regulations applicable to your personal information transferred to the United States may be different from the laws in your country of residence.
 
Changes to this Policy
 
We may occasionally update this Policy to reflect changes in our practices. When we post modifications to this Policy, we will revise the “Effective Date” at the top of this Policy. If the changes are material, we will endeavor to notify you in advance of such changes taking place. If you object to any modification, your sole recourse is to notify us that you do not agree and to stop using the Platform and providing us with personal information. 
 
Contact Us
 
If you have any questions about this Policy, you may contact us at [email protected] or you may contact us by mail at: Spur Impact Association, PO Box 25208, Wilmington, DE 19899-5208.