Revised June 2019
Our Commitment To Privacy
ConnectionPoint Systems Inc. (including its subsidiaries, affiliates, agents, and service providers, collectively, “ConnectionPoint,” “we,” “us,” and/or “our”), operates an application (the “Application) and website (the “Website”), (collectively, the “Platform”) and provides its services (together with the Platform, the “Service”) to make it easy for users and visitors (“you,” and/or “your”) to raise money through your social networks for causes or projects you support and care about (the “Campaigns”).
If you are in Europe:
• for the purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”), the data controller is ConnectionPoint Systems Inc. and can be reached at the address set out below.
• “information” covers all personal data processed by us which means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly; and
Information We Collect
A) When You Visit Our Website
You are free to explore the Website without providing any Personal Information about yourself. When you visit the Website and register for the Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.
B) When You Use Our Subscription Service
C) Information Provided By Individuals
We may receive and store any information you enter on the Platform or provide to us in any other way that would allow us to identify you or contact you.
Examples of information we may collect from you include:
• If you set up a personal account, we collect your name, email address and, if you choose, social information (from the social networking site you connected with),
any photos that you upload to the Platform, your mailing address and phone number;
• Your email address and any information you provide to us when you email us, or Contact Us, or when you post on the Platform;
• Information you provide about yourself on your account page, a project page or anywhere else on the Platform. For example, if you use any third-party platforms, such as Facebook, LinkedIn, Google or Twitter, to share information about yourself on the Platform, we collect that information; or
• If you enter a sweepstakes, we collect your name, address and contact information to administer the sweepstakes and fulfill prizes and, to the extent permitted by law, to provide you with information on upcoming events, announcements, and sweepstakes.
• Personal Information can also include information about any transactions, both free and paid, that you enter into on the Platform, or publicly available information that we acquire from service providers.
You may also provide us with special categories of personal data under the GDPR (also known as sensitive data) about yourself and/or third parties such as health information. When you provide such information, we will seek your explicit consent unless it is being published in relation to your campaign.
If you do not want us to collect information about you, you can simply decide not to submit it to us. If you choose to decline to submit such information, you may not be able to take advantage of all of the services and products offered on the Platform.
D) Information Provided by Organizations If you are a charity or nonprofit (each a “Charity”) or a for-profit or social enterprise organization (each a “Business”), (collectively, an “Organization”) and you establish an account with us, we will collect the name, tax ID, and physical address of the Organization, and the name, email address, and phone number of the person who establishes a Organization account (the “Organization Contact”). We also may collect, if the Organization Contact chooses to provide it, additional descriptive information about the Organization including any photos uploaded to the Platform.
E) Passive Gathering of Information Electronically
1. Cookies When you interact with our Service, we try to make that experience simple and meaningful. To help optimize this experience we collect some information from you. When you visit our Platform, our web server sends a cookie to your computer or mobile device (as the case may be). Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application, and which store and sometimes track information about your use of the Platform (as the case may be). A number of cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to the Platform and will last for longer.
Some of the cookies used by the Platform are set by us, and some are set by third parties who are delivering services on our behalf. If ConnectionPoint stores a cookie on your browser, ConnectionPoint may only access our own cookie, not that of another company.
Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser 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. Please note, however, that by blocking or deleting cookies used on the Platform, you may not be able to take full advantage of the Platform.
2. Web Beacons
A web beacon is a transparent image file. Web beacons enable us 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 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 that then generates a record showing that the email has been viewed.
Web beacons may also recognize when the email was opened, how many times it was forwarded and which URL’s (links within the email) were clicked.
3. Pixel Tags
In addition, we use “Pixel Tags” (also referred to by Web beacons, 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 Web 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 e-mail messages in a format users can read, and they tell us whether e-mails 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.
F) Aggregate and De-Identified Information
From time to time, we may also ask you to provide us information that is not intended to allow us to identify you personally. This information may be aggregated and/or de-identified and used for our internal purposes or for creating reports for third-party partners, or otherwise shared with third parties for any lawful purpose, without your permission.
G) Information from Third Parties It may be necessary for us to obtain address or other information about you from third-party sources for fraud prevention or for legal compliance, to enforce our legal rights or to protect the rights of other users of the Platform and our Service.
How We Use Information
When you provide us with your information, we may use such information for a number of purposes, including:
• To facilitate communication between us and you including, without limitation, responding to your questions or comments, sending emails concerning our products and services including upcoming events, announcements, and sweepstakes, or to contact you for feedback regarding us, advertisers or business partners;
• To administer your account, process contributions, provide products or services to you and for our marketing and promotional activities;
• To provide a report to a Organization or an event supporting a Organization to whom you have made a contribution or to a fundraiser to whom you have made a contribution, supported a project or joined a team (even if you have marked the contribution as non-public);
• To provide a report to a partner or campaign organizer who is helping promote a Organization or an event supporting a Organization to whom you have made a contribution, including your name, email address, or other similar information;
• To provide a report to our advertisers or business partners that tells them who responded to a particular offer or to facilitate the fulfillment of an order that you have made with an advertiser or business partner;
• To provide you with important functionality changes to the Platform, new ConnectionPoint services and, to the extent permitted by law, special offers from ConnectionPoint and reputable third parties that we think you will find valuable;
• To customize, analyze, adjust and improve the Platform to meet our advertisers’ or business partners’ needs and expectations;
• To enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws; • To send emails to friends based on your instructions as discussed in E-mail Communications to You and Your Friends; or
• To associate users’ activities, customize content, or tailor advertising to those users across different devices and browsers (for instance, tablets, mobile devices and applications, and websites).
ConnectionPoint may also use the publicly available information you provide to help promote your campaign on media websites such as our own website, television, radio, local or national newspapers, printed newspapers, blogs, forums and other electronic properties.
For the purposes of the GDPR, we may use your information in the above ways as this is necessary: (i) to fulfill our obligations under our contract with you or in order to take steps at your request prior to entering into a contract; (ii) for our legitimate interest to maintain our relationship with you or protect you and us against fraud; or (iii) to comply with legal obligations.
We may use third-party web analytics services on our Service, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Passive Gathering of Information Electronically” section to help us analyze how users use the Service, including by noting the third-party website from which you arrive, and provide certain features to you. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Service. This information may be used to place interest-based advertisements on the Platform. This may result in you seeing advertisements for our Platform when you visit other websites. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
We may use third-party advertising technologies that allow for the delivery of relevant content and advertising on our Platform, as well as on other websites you visit. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Also, third parties whose products or services are accessible or advertised on our Platform may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the website as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on our website, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the website. We may provide our customer information (such as a hashed version of your email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to target or “retarget” you with ads when you visit other websites and mobile applications. (You may opt out of these many of these service providers as described in the next paragraphs.)
If you receive tailored advertising on your computer through a web browser, you can learn more about such tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, by visiting the European Interactive Digital Advertising Alliance Consumer Ad Choices link for EU based advertising or for US based advertising either: (i) the Network Advertising Initiative’s Consumer Opt-Out link or (ii) the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.
Please note that to the extent advertising technology is integrated into our website or other websites that you visit, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Retention of Your Information
We will only retain personal 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 your information, we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it in accordance with our internal policies.
Accessing or Changing Your Information
ConnectionPoint allows you to change or correct inaccuracies in some of your information by logging into your account and making changes at any time. If you have questions about, or wish to review or correct the information we maintain about you, you may send an email to firstname.lastname@example.org or through the Contact Us feature. For more information on your rights if you are in Europe or Canada, please see “Users in Europe or Canada” below.
Email Communications to You and Your Friends
When you send an email to ConnectionPoint, we may retain your email address and the contents of the email you send.
Disclosure of Information to Third Parties
ConnectionPoint may give, share, sell or trade your information to or with any third parties under the following circumstances:
A) Charities, Businesses, Event Organizers, Event Partners, & Sweepstakes Partners
When you make a contribution or sign up to, volunteer, fundraise, enter a sweepstakes, or register for an event for a Charity, for a Business or for an organization or event associated with fundraising (e.g., a marathon, walkathon, concert or similar), ConnectionPoint shares with the Fundraiser, Organization, Event Organizer, Sweepstakes Partners and Event Partners your name, address, email address, contribution amount, date of transaction, transaction identification number and may also include the name of the project, and event associated with the contribution. This information may be used by the Organization to facilitate your participation in an event, to accept and process your contribution, to issue a tax receipt or to contact you as otherwise permitted by law. If you wish to stop receiving communications from a Charity, Business, Event Organizer, Sweepstakes Partners, or Event Partner, please contact the Charity, Business or Event Organizer or Event Partner directly.
B) Business Partners
C) Fulfillment of Services
We may retain other companies and individuals to perform certain functions on our behalf. Examples include, but are not limited to, companies and individuals who: (i) administer the ConnectionPoint accounts; (ii) process contributions; (iii) conduct surveys or promotional activities; (iv) deliver products; or (v) provide customer support, web hosting, internet service, and data analysis. Such third parties may be provided with access to your information needed to perform their functions but may not use such information for any other purpose.
D) Compliance with Law and Fraud Protection
E) Sale or Transfer of Information
Credit Card Information
ConnectionPoint does not collect, store or otherwise maintain any credit card or bank account information from individuals who make a contribution through the Platform. Contributions, including information associated with your credit card, are processed by our partners, including PayPal, Stripe and WePay.
PayPal, based in San Jose, CA, is a global electronic payment and credit card processor. All contributions made through PayPal will go directly from the contributor’s PayPal account, credit card or bank account to the Organization’s PayPal account. All information associated with your use of PayPal will be handled in accordance with the terms of PayPal’s User Agreement. When you contribute through ConnectionPoint and use PayPal to process your contribution, you agree to abide by PayPal’s User Agreement.
Stripe, based in San Francisco, CA, is a global electronic payment and credit card processor. All contributions made through Stripe will go directly from the contributor’s credit card or bank account to the Organization’s Stripe account. All information associated with your use of Stripe will be handled in accordance with the terms of Stripe’s User Agreement. When you contribute through ConnectionPoint and use Stripe to process your contribution, you agree to abide by Stripe’s User Agreement.
WePay, based in Palo Alto, CA, is a credit card processor that operates in the United States, Canada and the United Kingdom. Contributions will appear on the contributor’s credit card statement under the name of the Organization to whom they contributed. All contributions made through WePay go directly from the contributor’s credit card or bank account to the Organization’s WePay merchant account.
All information associated with your use of WePay will be handled in accordance with the terms of WePay’s Terms Of Service. When you contribute through ConnectionPoint and use WePay to process your contribution, you agree to abide by WePay’s Terms Of Service.
Information You Publicly Post
Any information you post publicly on the Platform including text, images, audio, video, graphics and other content or materials of any nature (“Publicly Available Content”) is available to the public without any expectation of privacy or confidentiality. Copies may remain viewable in cached and archived pages or if other users have copied or stored your Publicly Available Content even if you remove the Publicly Available Content. To request removal of your information from these areas of the Platform, contact us using the information below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to do so and why. Minors may contact email@example.com to remove any such information immediately. The profile you create on our Platform will be publicly visible.
Information You Provide to Facebook and Other Social Networking Sites
Users In Europe or Canada
If you are in Europe, you have the following rights (if 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 defence 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 sending the request to us at the email address or mailing address set forth under “Contacting ConnectionPoint”. For your own privacy and security, at our discretion we may require you to provide your identity before providing the requested information. Please note that ConnectionPoint may take up to 30 days to fulfill such request.
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.
Important Disclosures, Practices and Contact Information
A) Third-party Links
The Platform may contain links to third-party websites. Please be aware that ConnectionPoint cannot control and is not responsible for the information collection practices of such websites, which may differ from those of ConnectionPoint. We encourage you to review and understand the privacy policies of these web sites before providing any information to them.
B) Data Security
We maintain a variety of safeguards designed to protect your information from unauthorized access, loss, misuse, alteration and disclosure. For example, we use industry accepted tools and techniques to protect against unauthorized access to our systems. We implement both physical and technological protocols to limit access to your information. These safeguards and tools vary based on the sensitivity of the information that we maintain about you.
You should be aware, however, that ConnectionPoint has no control over the security of other websites on the Internet that you might visit even when a link may appear to those websites from our ConnectionPoint. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your information.
We want you to feel confident using the Platform. However, no system can be completely secure. Therefore, although we take measures to secure your information, we do not promise, and you should not expect, that your information, searches or other communications always will remain secure. In the event of a breach of the confidentiality or security of your information, we will notify you if reasonably possible and as legally required so that you can take appropriate protective steps. We may notify you under such circumstances using the email address(es) we have on record for you. You should also take care with how you handle and disclose your information.
The Platform is not intended for persons under the age of 13 (or 16 in Europe). ConnectionPoint does not knowingly market to, or solicit information, accept service or collect information from any person under the age of 13 (or 16 in Europe). If ConnectionPoint becomes aware that any person submitting information to the Platform is under the age of 13 (or 16 in Europe), we will attempt to delete the account and any related information as soon as possible. We require that only persons 13 years of age or older (or 16 or older in Europe) use the Platform. By using the Platform, you hereby represent that you are at least 13 years old (or 16 in Europe).
F) Users from Outside Canada
The Platform is hosted in the Canada and with third party service providers in the United States and is governed by Canadian law. If you are visiting the Platform from outside Canada, please be aware that your information may be transferred to, stored and processed in Canada where our servers are located and our central database is operated. The data protection and other laws of Canada and other countries might not be as comprehensive as those in your country.
G) No Rights of Third Parties