Last updated on November 12th 2019
2. WHO MAY USE OUR SERVICE
You may use the Service if you are 18 years or older and are not barred from using the Service under applicable law. If you are between 13 and 18, you must have permission from your legal guardian before you are permitted to use the Service. You are not permitted to use the Service if you are under 13 years old. If we become aware that a minor under the age of 13 has provided us with personal information, we will take steps to delete that information.
3. INFORMATION WE COLLECT ABOUT YOU
Account Information. If you register for or use Service, we, or our affiliates, partners and/or vendors acting on our behalf, may collect the following types of information:
- Contact Information. We may collect your name, address, phone, email and other similar information;
- Identity Verification Information. We may require you to provide additional information that we may use and provide to partners and or vendors acting on our behalf to verify your identity. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, bank and credit card information, or other personal information. We may also obtain information about you from third parties such as credit bureaus and identity verification services including personal and/or business credit reports under the Fair Credit Reporting Act;
- Ongoing Information Collection. When you use our Service, we collect information about your donations (including funding account information). Please be aware that any donations you make will be visible by default to other users of the Service. You can limit this sharing in your account settings. We also collect information about your other activities on our Service (including the content you view and your favorite causes/charities) and we may continuously collect information about your computer, mobile device, or other access device to protect the Service, members and us, for fraud prevention and remediation purposes, to monitor for irregular activity with your account, and to identify known malicious software or other activity that may harm us or our members;
- Plaid Information. If you make a donation using our “Round Up” feature of the Service, we will also collect your entire purchase history for the account or payment method which you provide the Service access to. In order to do this, we work with Plaid to get information from the financial institutions and other financial service providers that maintain your financial accounts. This information includes, but is not limited to, account information, information about your account balances (including current and available balances), information about credit accounts, including statement due dates and balances owed, payment amounts and dates, information about account transactions, including amount, date, type, quantity, price, and a description of the transaction, and other information.
The data collected via Plaid from your financial accounts may include information from all your sub-accounts (e.g., checking, savings, and credit card) accessible through a single set of account credentials
- Funding and Transaction Information. We may collect and store your funding instruments, along with other related transaction information. For instance, in the event that you link to a credit card for the purpose of making a Round Up Donation, we will obtain and store a list of your monthly transactions associated with the credit card in order to calculate the applicable donation amount for the month by rounding up each purchase you made using the credit card in that month. If you use Apple Pay to make a donation (including participating in the $1 Giveaway), you acknowledge and authorize us to obtain and store information associated with your Apple Pay that your privacy settings on the Apple Pay permit us to access. We will use such information solely for the purpose of providing the Service to you (such as presenting the credit card information to you when you wish to make a credit card based donation in the future).
Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you request information about our Service, register for our newsletter, or otherwise communicate with us.
Customer Service. We may also collect information you may disclose to our member support team in order to resolve problems you report.
Interactive Features. We may offer interactive features such as forums, blogs, commenting functionalities, and social media pages. We and others who use our Service may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.
Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in ChangeUpand/or the Service. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Personal information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
Information We Collect Automatically. We may collect certain information automatically when you use the Service. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Service, information about the links you click, information about how you interact with the Service, including the frequency and duration of your activities, and other information about how you use the Service. Information we collect may be associated with accounts and other devices.
- Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Service may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Service that collects information about engagement on the Service. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Analytics. We may also use Google Analytics and other service providers to collect and process analytics information on our Service. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.
Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations. For example, if you access our Service through a third-party application, such as a third-party login service (e.g., Google or Facebook), we may collect information about you from that third-party that you have made available via your privacy settings.
4. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for a variety of business purposes, including:
To Provide the Service or Information Requested, such as:
- Fulfilling our contract with you;
- Reviewing your transactions and calculating donation amounts;
- Processing payment card and/or other financial information to facilitate your use of the Service;
- Responding to questions, comments, and other requests;
- Providing access to certain areas, functionalities, and features of our Service; and
- Answering requests for customer or technical support.
Administrative Purposes, such as:
- Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Measuring interest and engagement in our Service;
- Developing new products and services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Carrying out audits;
- Preventing and prosecuting potentially prohibited or illegal activities;
- Enforcing our agreements; and
- Complying with our legal obligations.
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Service, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
- Operationally Necessary. This includes Technologies that allow you access to our Service, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance Related. We may use Technologies to assess the performance of our Service, including as part of our analytic practices to help us understand how our visitors use the Service;
- Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Service. This may include identifying you when you sign into our Service or keeping track of your specified preferences, interests, or past items viewed;
- Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Service or on third party sites.
5. SHARING YOUR PERSONAL INFORMATION
We may share your personal information with the following categories of third parties:
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Service; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision IT and related services.
Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.
Third-Party Applications. If you authorize applications or third-party integrations on or using our Service, these parties may receive detailed information about your account, your use of the Service, donation history or even the ability to take actions on your behalf. Information collected by these applications or third-party integrations are subject to their terms and policies.
Affiliates. We may share personal information with our affiliated entities.
Advertising Partners. Through our Service, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.
APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Service. APIs and SDKs may allow third parties including advertising partners to collect your personal information in order to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
6. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
7. YOUR CHOICES
General. You may have the right to object to or opt out of certain uses of your personal information.
Mobile Devices. We may send you push notifications through our App. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect precise location information if you use our App. You may opt-out of this collection by changing the settings on your mobile device.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/,https://youradchoices.ca/choices/, and www.aboutads.info/choices/.
Please note you must separately opt out in each browser and on each device.
8. INDIVIDUAL RIGHTS IN PERSONAL INFORMATION
For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
If you are a California resident, you have the right not to receive discriminatory treatment by ChangeUp for the exercise of your rights conferred by the California Consumer Privacy Act.
9. HOW WE SAFEGUARD YOUR PERSONAL INFORMATION
We take steps to protect the information we collect by maintaining reasonable technical and organizational safeguards. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable laws, we do not accept liability for unauthorized disclosure.
By using the Service or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service, by mail or by sending an email to you.
10. THIRD PARTY WEBSITES/APPLICATIONS
The Service contains links to other websites/applications and other websites/applications may reference or link to our Service. These third-party services are not controlled by us, and ChangeUp does not endorse or make any representations about third party websites or applications. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
11. DATA RETENTION
12. SUPERVISORY AUTHORITY
If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
14. CONTACT INFORMATION