For the purposes of this privacy notice, the term “personal data” means any information which identifies you or which allows you to be identified when combined with other information.
Quick Guide to Contents
- Important information and who we are
- Data we collect
- More information about our cookies
- How we use your data and our lawful basis
- Disclosures of your personal data
- Your rights and choices
- Your California privacy rights
- Third-party content, links, and plug-ins
- International transfers
- Data security
- Data retention
- Our commitment to children’s privacy
- Questions/Contact Us
1. IMPORTANT INFORMATION AND WHO WE ARE
For residents from the European Economic Area (EEA) or European Union (EU), Authentifi, Inc. is the controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out in the “Questions/Contact Us” section below.
2. DATA WE COLLECT
There are several ways we may obtain information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. This includes data that identifies you personally whether directly (i.e. your name) or indirectly (i.e. information about your online use). See More
A. Information you provide directly
We may directly collect personal data whenever you interact with us or choose to share it with us. This may include when you sign up for our products or services; complete a form on our Site requesting us to contact you; create an account on our Site; subscribe to our service or publications; request marketing materials or newsletters be sent to you; make a purchase; enter a competition, promotion or survey; or provide us with feedback
The personal data we collect from you generally falls within one of the following categories:
- Identity Data: includes first name, maiden name, last name, username or similar identifier and title.
- Contact Data: could include mailing address (for organization admin), email address and telephone numbers.
- Transaction Data: includes payments details of transactions to and from you and details of products and services you have purchased from our merchant partners.
- Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Content Data: includes any content which you upload onto the Site such as comments and other text or images that contain personal data.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
Providing personal data is always optional. However, some personal data must be provided in order to participate in certain programs, activities, or events (e.g., to sign up for a newsletter, or communicate with us), and withholding this information might limit or altogether eliminate certain site functions.
B. Information we automatically collect
- Technical Data: We may automatically collect your Internet Protocol (IP) address or other unique identifier or information from the computer, mobile device, tablet or other device you use in connection with the Site, including your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other devices you use to access this Site. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Usage Data: We may automatically collect your Internet Protocol (IP) address or other unique identifier or information from the computer, mobile device, tablet or other device you use in connection with the Site, including your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other devices you use to access this Site. We may also receive Technical Data about you if you visit other websites employing our cookies.
Please see “More information about our cookies” below for further details.
C. Information we receive from third parties
We may use third parties to support our services, better understand who is using the Site, how people are using the Site, and to help us or those third parties serve more targeted advertising to you across the Internet. We may receive personal data about you from third parties and public sources as set out below:
- Technical Data from the following parties: (i) analytics providers (ii) advertising networks; and (iii) search information providers.
- Identity, Profile and Contact Data from publicly available sources such as Companies House.
- Identity, Profile and Contact Data from data providers who obtain such data from publicly available sources.
We may use this information to help us maintain the accuracy of the information we collect, personalize your experience with the Site, target our communications so that we can inform you of products and services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.
D. Combination of information
We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site and App, as well as information collected offline, across other computers or devices that you may use, and from third party sources.
3. MORE INFORMATION ABOUT OUR COOKIES
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The types of cookies we use on our Site are:
- Strictly Necessary Cookies. We use Strictly Necessary Cookies to operate our Site. These cookies are essential to enable you to move around the Site, use its features and to log into secure areas of the Site.
- Functionality Cookies. We use Functionality Cookies to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by name and remember your preferences and various settings on our Site
- Analytical/Performance Cookies. These cookies collect information about how many people are using our Site and how they are moving around it when they’re using it. For example, the pages visited most often, how people are moving from one link to another, and if they get error messages from certain pages. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
- Targeting Cookies. These cookies are used to deliver advertisements that are more relevant to you and your interests. They remember that you have visited our website, the pages you visited and the links you have followed. This information may be shared with other organizations such as our advertising partners.
To learn more about how to control cookies and your advertising choices relating to the collection and use of your information, please see the “Your rights and choices” section below.
4. HOW WE USE YOUR DATA AND OUR LAWFUL BASIS
A. Lawful basis for using your personal data
We will only use your personal data when the law allows us to. Most commonly, we will have a lawful basis to process your personal data:
- Where we need to process your information in order to provide you with the products or service you have requested or to perform the contract we are about to enter into or have entered into with you.
- Where you have consented to such processing.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests — e.g., preventing fraud; ensuring our network and information systems are secure; conducting data analytics; enhancing modifying or improving our services; identifying usage trends.
- Where we need to comply with a legal or regulatory obligation.
- Under the terms of any Verified Donations’ Program Agreement.
You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
B. Purposes for which we will use your personal data
We may use the data we collect from and about you for any of the following purposes:
- To respond to your inquiries, fulfill your requests, and contact and communicate with you when necessary;
- To register you as a new customer/user;
- To place a charitable class donation through the Site, or to process the creation of a charitable class or collect funds;
- To receive a donation from a purchase made on a merchant partner in the Change Commerce program;
- To enable you to partake in a prize draw, competition or complete a survey;
- To provide you with customized Site content, targeted offers, and advertising on the Site or via email, or across other websites, mobile applications, social media or online services, and to measure or understand the effectiveness of the advertising we serve to you;
- To make suggestions and recommendations to you about goods or services that may be of interest to you;
- To use and disclose your credit/debit card information to process payments and prevent fraud;
- To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- To review the usage and operations of our Site, develop new products or services, and conduct analysis to enhance or improve our content, products, and services;
- To use data analytics to improve our Site, products and services, marketing, customer relationships and experiences; and
- For other purposes disclosed at the time you provide your information or otherwise with your consent.
We may also use your data in an aggregated or de-identified format (such as statistical or demographic data) for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature.
C. Profiling/Automated Decision-Making
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
In some instances, we process your personal data for the profiling purposes described above using automated or semi-automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data. We will not make any decisions based solely on automated or semi-automated decision-making that have a significant impact on you.
You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share the personal data we collect from or about you as described below. See More
A. Sharing of Information by You
The Site offers many ways to find, enjoy, and share content. Your activity in connection with the Site may include filling out surveys, reviewing and rating products or services, inquiring about or purchasing products or services, participation in online communities, “liking” or “sharing” our content to your social media accounts or pages or otherwise interacting with the Site. Any information you may disclose on our Site, in blogs, on message boards, in chat rooms, or on other public areas on the Site or other third-party websites, applications, or services that this Site may link to, becomes public information. Please exercise caution when disclosing personal information in these public areas.
B. Sharing of Information by Us
We may share your personal data with the following categories of recipients:
- Service Providers: We may share your information with third party service providers that provide business, professional or technical support functions for us, help us operate our business and the Site, or administer activities on our behalf. This may include service providers who provide IT and system administration services; service providers who provide customer service tools, such as online chat services and helpdesk services; or third party analytics partners to analyze Site traffic and understand customer needs and trends.
- Third parties who provide personalized icons for use on our Site.
- Participating Utilities and Service Providers: We may share your information with the participating utilities or other service providers where you have chosen to donate, if you consent to such disclosure.
- Professional Advisors: We may share your information with our professional advisers, including our lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Advertising Partners: We may share your information with our third party advertising partners to advertise products and services to you on third party sites which are tailored to meet your preferences and likely interests.
- Legal Obligations; Safety: We may access and disclose your information to third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; or (c) protect or defend our legal rights or property, our Site or customers.
- Other: We also may share your data as disclosed to you at the time of collection.
6. YOUR RIGHTS AND CHOICES
By law, you have a number of rights when it comes to your personal data. If you wish to exercise these rights with regards to the data that we hold, please send an email to firstname.lastname@example.org or contact us using the details set out in the “Questions/Contact Us” section below.
Further information and advice about your rights can be obtained from the data protection regulator in your country. We provide you with a number of rights and choices concerning your personal data. See More
A. For EU/EEA Data Subjects
For our users that live in the EU or EEA, you may have certain rights under data protection laws in relation to your personal data. If you wish to exercise these rights with regards to the personal data that we hold, please contact us. Further information and advice about your rights can be obtained from the data protection regulator in your country.
- Right to rectification. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- Right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to ask us to delete or remove personal data where there is no compelling reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e., if you no longer want to be contacted with potential opportunities).
- Right to restrict processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Right to request transfer of personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent. If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Pursuant to applicable data protection law, we may be entitled to refuse to act on the request.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). If requests are repetitive or excessive, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us verify and confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
B. Cookies, Tracking Options and California Do Not Track Disclosures
For California Residents: Certain parts of our Site require cookies. You are free to adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.
C. Interest-Based Advertising Choices
To understand your choices for receiving more relevant advertising on the Site or across other websites and online services, please review the information below.
- DAA: To opt out from the collection and use of information about your online activities for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit: http://www.aboutads.info/choices/.
- EDAA: To opt out from the collection and use of information about your online activities for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) participating companies, please visit: http://www.youronlinechoices.eu/.
- NAI: To opt out from the collection and use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) member companies, please visit: http://www.networkadvertising.org/choices/.
On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Even if you opt out using one of the methods above, you still may receive advertising from us that is not customized based on your use of the Site, or that includes advertising from other third parties if they are not a DAA, EDAA, or NAI participating company.
D. Other Choices Concerning the Use and Disclosure of Your Information
We provide you with the opportunity to update you information or opt-out of having you information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product order or servicing of your product. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Your instructions to limit the use of your information for marketing purposes will be processed as soon as reasonably practicable.
7. YOUR CALIFORNIA PRIVACY RIGHTS
For California residents: If you are a California resident, you may request information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes. To make such a request, please contact us at email@example.com. You must put the statement “Your California Privacy Rights” in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Non-affiliated third parties are independent from Authentifi and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.
8. THIRD-PARTY CONTENT, LINKS, AND PLUG-INS
This Site may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.
9. INTERNATIONAL TRANSFERS
We or our service providers may process, transfer, and store information about our users on servers located in a number of countries outside the EU or EEA, including in the United States. Since we are committed to protecting your information, we take steps to ensure that there are appropriate safeguards in place when we transfer that data. See More
If/When we transfer your personal data out of the EU or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented :
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use approved standard EU model clauses by the European Commission, which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
10. DATA SECURITY
We have put in place reasonable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and/or any applicable regulator of a breach where we are legally required to do so.
11. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
You can request further details of retention periods for different aspects of your personal data by contacting us.
12. OUR COMMITMENT TO CHILDREN’S PRIVACY
Protecting children’s privacy is important to us. We do not direct the Site to, nor do we knowingly collect any personal information from, children under the age of 16 . If we learn that a minor has provided personal information through the Site, we will use reasonable efforts to remove such information from our files.
14. QUESTIONS/CONTACT US
2020 Pennsylvania Avenue, NW, #434
Washington, D.C. 20006
Last updated: August 13th, 2018