Privacy Policy

Date of Last Revision: September 20, 2014

GiveStep, Inc. ("GiveStep") respects your privacy and, to that end, has established the following privacy policy (the "Policy") for the website at www.givestep.com (the "Site") owned and operated by GiveStep, including GiveStep’s fundraising platform that is available on the Site (the "Platform"), and any incidental or related services provided by GiveStep (collectively with the Site and the Platform, the "Service"). This Policy explains how your information, including personally identifiable information, is collected, used and disclosed by GiveStep, and applies to all information, including personally identifiable information, collected by GiveStep through the Service.

By using the Service in any manner, including browsing, accessing, or completing the registration process on, the Site, you consent to the collection, use and disclosure of your information, including personally identifiable information, as outlined in this Policy.

GiveStep reserves the right to revise this Policy, at any time and in its sole discretion, without notice, by posting the revised Policy on the Site. It is your responsibility to check this Policy periodically for revisions. Your continued use of the Service following that posting constitutes your acceptance of the revised Policy. If GiveStep makes any change to this Policy, it will update the "Date of Last Revision" above.

This Policy is a part of the Terms of Use of GiveStep

Collection of Information

GiveStep’s Platform, which is a part of the Site and available to registered users of the Site, provides a social fundraising platform that integrates the world of sports and charitable giving in a fun and flexible manner. GiveStep allows use of the Site by (1) those charitable organizations or purposes that are raising money and are listed on the Site ("Beneficiaries") and (2) those individuals or entities that are donating money to benefit one or more of those Beneficiaries ("Donors"). The term "Beneficiary" also includes GiveStep Charitable Foundation, Inc. (the "Foundation"). More information about the Foundation and its role is available in the Terms of Use.

Some portions of the Site can be used by a visitor to the Site without the need for having registered and creating an account on the Site. In order to use the Platform for raising or making donations, a visitor to the Site will need to sign up for an account by completing the registration process on the Site as a Donor or Beneficiary (each, a "User"). A "User" also includes any individual that registers and creates an account on the Site on behalf of an entity (including an association) that is a Beneficiary or Donor. The following is a list of the categories of information, including personally identifiable information, that GiveStep may collect from visitors to the Site, including Users.

Categories of Information Collected from Users: If you register and create an account on the Site:

• your name, log-in and password details, and email address,
• if you choose to provide it: your mailing address, phone number, photo, display name, birthday, gender and other optional profile information that you can choose to add to your account,
• any additional information or documentation that you voluntarily provide to GiveStep to confirm or verify your eligibility to use the Service, or any photos or other content you post or upload to the Site,
• if you are a Donor: credit card and other payment information (note that this information is initially collected on the Site’s servers but is immediately transferred to, and stored on, the servers of GiveStep’s third-party payment gateway service provider (the "Payment Gateway Provider"); this information is not stored on GiveStep’s servers), and your pledge information, including the names of your suggested Beneficiaries and the amounts of each donation generated,
• if you are a Beneficiary (and whether or not the Beneficiary has registered and created an account): any information contained in reports or lists prepared by the Internal Revenue Service or a third-party provider that contain, among other things, lists of organizations eligible to receive tax-deductible charitable contributions (the "Third Party Charity Lists") that GiveStep obtains from time to time, and
• if you contact GiveStep, including to report a problem or to submit queries, concerns or comments regarding the Service: any personally identifiable information that you provide about yourself in that communication, as well as the content of that communication, whether done via email, mail, "Contact GiveStep" page, phone or otherwise.

Categories of Information Collected from All Visitors and Users: GiveStep may also automatically receive and record other information, including personally identifiable information, when you visit the Site as a function of activity on GiveStep’s server logs or the use of cookies or web beacons, including your IP address and browser type.

• Cookies: Cookies are small files that a website or its service provider transfers to your computer’s hard drive through your web browser (if you allow it and the browser is capable of it) that enables the website’s or service provider’s systems to recognize your browser and capture and remember certain information. GiveStep may set and use cookies to enhance your experience, such as retaining your personal settings and preferences. Cookies identify the computer being used to access the Site, but will not identify you, personally. You may be able to set your browser to prevent or reject cookies, or you may be able to manually delete any cookies set; however, that may lead to difficulty in accessing all pages and features of the Site. All browser types operate differently with respect to preventing or deleting cookies.
• Third Party Analytics Tools: GiveStep may also use third party services, such as Google Analytics, to collect certain information about how you use the Site via cookies or other technologies. The information collected and used in this manner is anonymous, non-personally identifiable information that may include information about your computer, your browsing actions and patterns, the details of your visits to the Site, your location, the resources that you access and use on the Site, information about your internet connection, your IP address, your operating system and your browser type. This information will be transmitted to and stored by Google Analytics on its servers. Google Analytics will use this information for the purposes of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google Analytics may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google Analytics’ behalf. Google Analytics will not associate your IP address with any other data held by Google Analytics. By using the Site, you consent to the processing, use and disclosure of information about you by Google Analytics in the manner and for the purposes described above. Google Analytics has created a tool, which allows you to opt out of Google Analytics: https://tools.google.com/dlpage/gaoptout. "Google" and "Google Analytics" are trademarks or registered trademarks of Google, Inc.
• Non-Personally Identifiable or Aggregated Information: GiveStep may collect anonymous, non-personally identifiable information about you, as well as aggregated or statistical data that is not intended to identify you personally, for GiveStep’s own internal purposes, including modifying the Site in order to improve your experience, or for purposes of sharing with third parties for marketing, advertising, or other purposes.

Use of Information

GiveStep may use the information, including personally identifiable information, collected from you in any of the following ways:

• to make sure that you meet the Site eligibility requirements, and to comply with state and federal law,
• to provide you with the Service, including processing your pledges or donation transactions, processing your payments and, in some cases, preparing your tax receipts on the Foundation's behalf,
• to create and administer your account, including identifying you when you sign-in to your account, and, under the circumstances detailed below, to share your information with other Users,
• to personalize your experience on the Site,
• to analyze, modify or improve the Service, including the Site,
• to contact you regarding your use of (or any changes to) the Service, including the Site,
• to facilitate communication between GiveStep and you, including responding to your questions or comments,
• to interact with, or provide reports to, GiveStep’s agents, service providers, contractors and other third parties who provide GiveStep with certain fulfillment and other services in connection with running and providing the Service, including the Site,
• to send periodic emails, including to notify you of payments scheduled for processing, and confirmation of payments after processing, for donations resulting from your pledge, and
• to prevent illegal activities or conduct, to prevent fraud or intellectual property infringement, to enforce GiveStep’s agreements with you, and for other legally permissible purposes.

Email and Opt Out:

Email addresses provided, including for registration or pledge creation, may be used by GiveStep to send Users information and updates pertaining to their pledge/donation, including tax receipts (where applicable), to respond to queries or other communication that you send to GiveStep.

Email addresses may also be used by GiveStep to provide Users with occasional GiveStep or GiveStep partner news, updates, promotions, related product or service information, etc. For these occasional emails, if at any time you would like to unsubscribe from receiving them, detailed unsubscribe instructions will be located at the bottom of these types of emails. You may also unsubscribe from them via your account on the Site.

Sharing Information with Other Users, Visitors to the Site and Beneficiaries:

By registering for the Site and creating a User profile, you may allow others to view your information, including personally identifiable information. Your account will have a public-facing profile page, with the display name of your choice, that can be viewed on the Site by other Users and any other visitors to the Site. Your profile page contains your picture (if you submitted one), a counter of your donation amounts and pledges, an activity feed (including donation amounts and names of suggested Beneficiaries), a pledge activity summary (of active and completed pledges), and a "Follow" button that other Users can click on to follow you. To change or hide certain of these features, you must change the applicable settings from your account.

Please note that the Site contains basic profile pages for Beneficiaries that Donors can use to select a suggested Beneficiary for a pledge, and that these basic profile pages (including the content or information contained in those pages) are initially based solely on the information contained in the Third Party Charity Lists (and not from the applicable Beneficiary). If a Beneficiary wishes to update or otherwise modify its basic profile page, it must first register on the Site to be a User and then "claim" its basic profile page. The existence of a basic profile page on the Site does not, in and of itself, signify that a Beneficiary has registered to be a User.

As a Donor, you can elect, through your account, to have GiveStep share your name, email address and phone number with Beneficiaries. Each Beneficiary has its own policies regarding privacy of donor information. As such, you should contact the particular Beneficiary directly to learn about their privacy policies.

Certain Beneficiaries (other than the Foundation), as a matter of their own operational policies, have a requirement for collecting information, including personally identifiable information, from all persons who make donations and, in certain cases, to use such information for, among other things, solicitation of such persons for additional donations, reporting to governmental taxing agencies or providing tax receipts. This information may include some or all of the following information: (1) name, (2) email address, (3) mailing address, (4) date of birth and (5) gender. When a Donor sets up a pledge using the Platform and identifies any such Beneficiary as its suggested Beneficiary, the Donor (i) will be prompted by the Site to provide any such required information that has not been previously collected from it during account registration on the Site or subsequently in connection with the Service (and it will not be able to finish setting up that pledge without providing such information), and (ii) GiveStep will automatically share with such Beneficiary all information required by such suggested Beneficiary. It is the Donor's responsibility for reviewing the applicable terms and policies (including privacy and data gathering, use or disclosure practices) of such Beneficiary before setting up that pledge, and for contacting such Beneficiary directly for all related matters (including to address any questions or concerns, or to determine whether it is possible, or how, to opt out of any solicitations or other communications from such Beneficiary). All such required information will be provided to such Beneficiary by US mail or electronically via the Site. By using the Service, including the Site, and providing its information, including personally identifiable information, to GiveStep, each Donor hereby consents to the provision, use and disclosure by GiveStep of your information as described in this paragraph, and as described below under "Disclosure of Information to Outside Parties".

Users should take precaution to avoid sharing or posting financial, personally identifiable or other sensitive information. Users acknowledge sole responsibility for any actions or information which violates the Terms of Use or misuses the information of any User.

Disclosure of Information to Outside Parties

GiveStep is not in the business of selling, renting or leasing your information, including personally identifiable information, to others.

GiveStep may share your information as described below:

• GiveStep may share your information, including personally identifiable information, with its agents, service providers, contractors and other third parties in order to allow them to provide certain services or perform certain functions or duties on GiveStep’s behalf, including: (1) hosting the Site, (2) processing payment of credit card transactions, (3) managing information, (4) internet service, data analysis, or enhancing the features and functionality of the Site, (5) administering GiveStep accounts, (6) conducting surveys or promotional activities, (7) delivering services or products, or (8) providing customer service. In all cases, these agents, service providers, contractors and other third parties are required to act in accordance with this Policy or have otherwise agreed to use this information only in order to provide or perform their respective services, functions or duties.
• GiveStep may provide certain of your information, including personally identifiable information, to the Foundation and other Beneficiaries, such as charities and non-profits, if you provide permission for them to contact you for purposes of solicitation or marketing via the contact preference settings of your account, or if GiveStep is required to provide certain of your information to comply with state and federal law, including federal election laws.
• As described above under "Sharing Information with Other Users, Visitors to the Site and Beneficiaries", GiveStep will automatically provide certain of your information, including personally identifiable information, to those of your suggested Beneficiaries (other than the Foundation) that require it. These Beneficiaries may use this information to contact you by email or regular mail for purposes of solicitation, marketing, providing tax receipts or otherwise. You must contact the Beneficiary directly to determine whether it is possible, or how, to opt out of any such solicitation, marketing or other use.
• GiveStep may share your information, including personally identifiable information, with your consent or pursuant to your instructions or preferences on the Site or your account.

GiveStep also reserves the right to disclose your information, including personally identifiable information, when GiveStep, in its sole discretion, believes that disclosure is necessary to:

• comply with laws,
• comply with subpoenas, warrants, court orders, government investigations, or other legal processes,
• enforce or apply the Terms of Use or GiveStep’s other policies or agreements,
• investigate, prevent or respond to allegations of fraud, intellectual property infringement, or other unlawful activity,
• protect the rights, property or safety of GiveStep, its agents, employees, personnel or others, or
• respond to an emergency or protect the personal safety of any person.

Also, in the event GiveStep goes through a business transaction, such as a merger, acquisition by another company, or sale of all or a portion of its assets, GiveStep reserves the right to sell or transfer to the acquiror or other party in such transaction all or any information, including personally identifiable information, that it has collected about you in connection with the Service. By using the Service, including the Site, and providing your information, including personally identifiable information, to GiveStep, you consent to the sale and transfer of your information as described in this paragraph.

GiveStep may also share anonymous, non-personally identifiable information, as well as aggregated or statistical data, with third parties for marketing, advertising, or other uses.

Any information, including personally identifiable information, that you publicly post on the Site is available to the public without any expectation of privacy. Copies may remain viewable in cached or archived pages or if other Users have copied or stored your publicly available information, even if you remove it from the Site. Users should take precaution to avoid publicly sharing or posting financial, personally identifiable or other sensitive information. In addition, any information, including personally identifiable information, about your account or other activities on the Site that you choose to publicly or otherwise post on social media or other websites, including Facebook or Twitter, is available to the public without any expectation of privacy, even if done using links or tools existing on the Site. "Facebook" and "Twitter" are trademarks or registered trademarks of their respective owners.

Accessing or Changing Your Information

GiveStep allows each User to change, delete or correct inaccuracies in, its information, including personally identifiable information, by accessing, and making desired changes on, its account on the Site. GiveStep may retain certain information as required by law or as is necessary for business purposes.

Security

GiveStep has put in place reasonable physical, electronic, and managerial procedures to prevent unauthorized access to your information and to maintain the accuracy of the information that GiveStep collects and stores. These security measures include, by way of example, password protected directories and databases to safeguard information or SSL (Secure Sockets Layered) technology to ensure that information is fully encrypted and sent across the Internet securely.

All payment information supplied by a User for its account via the Site is initially collected on GiveStep’s server but is immediately transmitted via Secure Socket Layer (SSL) technology and then encrypted into the Payment Gateway Provider’s database only to be accessible by those authorized with special access rights to such systems and required to keep the information confidential. GiveStep does not store any payment information on its servers. Your payment information will be stored on the servers of the Payment Gateway Provider until you remove that information from your account.

If you share your computer or use a computer that is accessed by the general public, then you should be sure to sign out of your account and close the browser window when you have finished your session in order to help ensure that others cannot access your information.

These policies seek to comply with all state and federal data privacy laws. GiveStep believes that it has implemented a robust approach to protect your security; however, because no security regimen is 100% effective, GiveStep cannot guarantee, and you should not expect, that your personally identifiable information or other communications will always remain secure. GiveStep will comply with applicable laws in notifying you of any data breach of your personally identifiable information.

Third-party Links

Occasionally, at its discretion, GiveStep may include or offer third-party products or services on the Site or links to third-party websites on the Site, including a link to the Foundation’s website. GiveStep cannot control and is not responsible for the information collection or privacy practices (or lack thereof) of these third parties or websites. These practices may differ significantly from GiveStep’s practices. GiveStep encourages you to review and understand the privacy policies of these third parties or websites before providing any information to them.

Childrens Online Privacy Protection Act Compliance

GiveStep is in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act). GiveStep does not collect any information from anyone under 13 years of age. The Site and other Service are all directed to, and may only be use by, people who are at least 18 years old or older.

California Residents

Because GiveStep values your privacy, it has taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. GiveStep, therefore, will not distribute your personally identifiable information to third parties, including for their direct marketing purposes, without your consent or in a manner that is contrary to this Policy.

Terms of Use

Please also review the Terms of Use establishing the use, disclaimers, and limitations of liability governing the use of the Site at https://www.givestep.com/tos.

Accessing the site from Outside the USA

If you are visiting the Site from a location outside of the United States of America, you will be connected through and to servers located within the United States, and all information you provide will be processed on web servers and GiveStep’s systems located within the United States. By providing your information to GiveStep or otherwise using the Site, you agree that all information, including personally identifiable information, will be used in accordance with this Policy and pursuant to United States law. The data protection and other laws of the United States might not be as comprehensive as those in your country. Please see the Terms of Use for GiveStep’s policy regarding the lack of eligibility of non-United States residents or entities to use the Service, including the Site.

Contact Information

If you have any questions or concerns regarding this Privacy Policy, please contact us by email to legal@givestep.com, or by sending GiveStep a message through the "Contact GiveStep" page (available at https://www.givestep.com/contact).