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Privacy Policy

Colorado Gives Foundation's Privacy Policy for ColoradoGives.org

LAST UPDATED September 10, 2024       Prior version


Who We Are

Welcome to the ColoradoGives.org website (the “Website”) operated by Colorado Gives Foundation (“Foundation,” “ColoradoGives.org”, “we,” or “us”). We take your privacy seriously and we know you do too.    This Privacy Policy (“Policy”) describes how we collect, process, and share Personal Data, your Rights & Choices , and other important information about how we handle your Personal Data.

Scope

This Policy applies to your use of our “Services,” which include our Website, fundraising platform, social media pages, and any other online services, as well as related phone support.

Except for processing by our service providers on our behalf ("Service Providers" as described below), this Policy does not apply to third party websites, products, or services. For example, we may manage portions of our Services directly, and third party businesses (such as payment processors) may manage others. Third parties, including nonprofit organizations who have registered to use our Services (“Nonprofits”), may operate or develop content on certain pages of the Website. In these cases, the terms, conditions, and privacy practices of the third party, not those of ColoradoGives.org, may govern your transactions, and we may have no control over the Personal Data collected.

 

How to Contact Us/Controller Information

The controller of your Personal Data under this Policy is Colorado Gives Foundation. You may contact our Data Privacy Team as follows:

Data Requests (available under the laws of certain regions) 

Visit our data request page or call (720) 898-5900

 

For further information on how to exercise data rights you may have in certain regions, please view the Regional Supplement below.

Physical Address:            

     Colorado Gives Foundation

     Attn: Privacy

     5855 Wadsworth Bypass, Unit A

     Arvada, CO 80003, U.S.A.

For other matters, please see our Contact Us page. 


Categories and Sources of Personal Data

The following describes how we process data relating to identified or identifiable individuals and households (“Personal Data”).

Categories of Personal Data We Process

Identity Data - Information such as your name; address; email address; account login details, e.g. username and password, avatar, or other account handles/usernames.

Contact Data - Identity Data we can use to contact you, such as email and physical addresses, phone numbers, social media or communications platform usernames/handles.

Device / Network Data - Although we may not collect all of the following depending on how you interact with us, this type of data may include:  browsing history, search history, and information regarding your interaction with a website, application, or advertisement (e.g. IP Address, MAC Address, SSIDs, application ID/AdID/IDFA, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, first party cookies, third party cookies, web beacons, clear gifs and pixel tags.

Transaction Data - Information about transactions you make with us or other Nonprofit organizations through our Website (such as, making an individual donation, and similar information). 

Payment Data - Information such as bank account details, payment card information, and relevant information in connection with a financial transaction.

Audio Data - Audio files and records, such as voicemails, call recordings, and the like.

Visual Data - Image files, such as photos you choose to add to your account profile, or photos uploaded by a Nonprofit to its fundraising page.

General Location Data - Non-precise location data, e.g. location information derived from your IP address.

Sensitive Personal Data -Personal Data deemed “sensitive” under Colorado or other applicable laws, such as racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, citizenship or citizenship status, genetic or biometric data, or personal data from a known child. We do not actively solicit Sensitive Personal Data, but we may process Sensitive Personal Data in some contexts if you choose to provide it, as described below. Payment Data may also be considered “sensitive” under certain laws, but that is described separately under the category of Payment Data.

User Content - Unstructured/free-form data that may include any category of Personal Data you choose to provide, e.g. data that you give us in free text fields on a Website form or email.

 

Sources of Personal Data We Process 

We collect Personal Data from various sources, which include:

Individuals - We receive Personal Data when individual users provide them to us, when they visit our Website or make a donation, or otherwise use our Services.

Non Profit Organizations - We receive Personal Data when a Nonprofit provides them to us, when they create a Non Profit Profile or fundraising page, or otherwise use our Services.

Service Providers - We receive Personal Data from the operator of our fundraising platforms, payment processors, and other service providers who transfer Personal Data to us when you create an account or make a donation, and other service providers performing services on our behalf.

Data we collect automatically - We (or service providers on our behalf) collect limited Device/Network Data and General Location Data about or generated by any device used to access our Website and Services.

Data Aggregators - We receive Personal Data from ad networks, data brokers, market research, or similar companies who provide us with additional Personal Data, e.g. Preference Data.

Social media companies - We receive Personal Data from social media companies when you use social media to sign-in to our Website, or when you interact with that social media company on or in connection with our Services.

Data we create - We, certain partners, social media companies, and third parties operating on our behalf, create Personal Data such as Aggregate Data or profiles based on our observations or analysis of other Personal Data processed under this Policy, and we may correlate this data with other data we process about you.


Data Processing Contexts

For Individuals

Website

Generally 

We process Device/Network Data, Contact Data, Identity Data, and General Location Data when you visit our Website. You may also be able to make a donation, register for an account, or enroll in marketing communications through our Website. If you make a donation, we or our service providers may also collect Transaction Data and Payment Data.

We use this Personal Data as necessary to operate our Website, such as keeping you logged in, delivering pages, etc., for our Business Purposes, and our other legitimate interests, such as:

  • ensuring the security of our Website, and other technology systems; and
  • analyzing the use of our Services, including navigation patterns, clicks, etc. to help understand and make improvements to the Services.

We may process this Personal Data for our Commercial/Fundraising Purposes.

Cookies and other tracking technologies

We process Identity Data, Device/Network Data, Contact Data, and General Location Data, in connection with our use of cookies and similar technologies on our Website. We may collect this data automatically.

We and our Service Providers may use cookies and similar technologies for the following purposes:

  • for “essential” purposes necessary for our Website to operate (such as maintaining user sessions, CDNs, and the like);
  • for “functional” purposes, such as to enable certain features of our Website (for example, to allow a donor to maintain an online shopping cart);
  • for “analytics” purposes and to improve our Website, such as to analyze the traffic to and on our Website (for example, we can count how many people have looked at a specific page, or see how visitors move around the Website when they use it, to distinguish unique visits/visitors to our Website, and what website they visited prior to visiting our Website, and use this information to understand user behaviors and improve the design and functionality of the Website); and  
  • for “social media” e.g. when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter.

We may also process this Personal Data for our Business Purposes and Commercial/Fundraising Purposes. See your Rights & Choices for information regarding opt-out rights for cookies and similar technologies.

Our Service Providers may view, edit, or set their own cookies or similar technologies on our websites. We, or third-party providers, may be able to use these technologies to identify you across platforms, devices, sites, and services. Third parties have their own privacy policies and their processing is not subject to this Policy.

User Account Registration

We process Identity Data, Contact Data, and Device/Network Data when you register and create an account for our Services, whether an individual donor account, or a Nonprofit account. We process Transaction Data and Payment Data if you associate one-time or recurring donations or other payment information with that account. We process Visual Data if you upload a profile photo.

We use this Personal Data to create and maintain your account, to provide the Services you request, and for our Business Purposes. We may process Identity Data and Contact Data for  Commercial/Fundraising Purposes.

Donations

We process Transaction Data, Payment Data, Contact Data, Identity Data, and Device/Network Data when you make a donation or purchase a Giving Card. We do not permanently store your Payment Data, except at your request. When you make a donation through a fundraising page on our Website, some of the information you provide (your first and last name, email address, mailing address, and Transaction Data such as the Nonprofit's name, date and time of your donation, and the amount of your donation) will be delivered to the creator of that fundraising page, whether it is created by the Nonprofit, or by an unrelated individual who creates the page on behalf of the Nonprofit ("Fundraising Page Creator"). We may also collect User Data if you provide it in free text or comment field on a donation page on our Website.  We may collect Sensitive Personal Data only if you provide it in a free text or comment field on a donation page, however we strongly discourage you from sending any Sensitive Personal Data to a Nonprofit through our Website or otherwise entering such data on our Website. We are not responsible for what the Fundraising Page Creator may do with any Personal Data they collect, and we disclaim all liability with regard to such uses.

We process this Personal Data as necessary to perform or initiate a transaction with you, process your order or payment, document transactions, and for our Business Purposes.

We may process Identity Data, Contact Data, and Device/Network Data for  Commercial/Fundraising Purposes.

Marketing Communications for Individuals

We process Contact Data, Identity Data, and Device/Network Data in connection with marketing emails, our newsletter, or similar communications, and when you open or interact with those communications. You may receive marketing communications if you consent and, in some jurisdictions, as a result of account registration or a donation.

We process this Personal Data to contact you about relevant Services and for our Business Purposes. We may use this data for our Commercial/Fundraising Purposes. See your Rights & Choices to limit or opt out of this processing.

Please note:  when you make a donation to a Nonprofit through Colorado Gives, you consent to receive marketing and other communications from that Nonprofit. Nonprofits have their own privacy policies and their processing is not subject to this Policy. See your Rights & Choices to limit or opt out of this processing.

Customer Service; Contact Us

We collect and process Identity Data, Contact Data, and User Content when you contact us, e.g. through a contact us form, for customer service, or when you report a problem with our Website. If you call us via phone, we may collect Audio Data from the call recording. We may collect Sensitive Personal Data only if you provide it to us in a free text field or over the phone, however we strongly discourage you from sending any Sensitive Personal Data to us.

We process this Personal Data to respond to your request, and communicate with you, as appropriate, and for our Business Purposes. If you consent or if permitted by law, we may use Identity Data and Contact Data to send you marketing communications and for our Commercial/Fundraising Purposes.

Posts and Social Media

We process Identity Data, Contact Data, and User Content you post (e.g. comments and social media posts, etc.) when you interact with us on social media platforms, such as Facebook, Twitter, and YouTube.

We process this Personal Data for our Business Purposes, and Commercial/Fundraising Purposes.

Posts may be public, or reposted on our Services. Content you provide may be publicly-available when you post it on our Services, or in some cases, if you reference, engage, or tag our official social media accounts on social media platforms.


For Nonprofits

Nonprofit Profile Registration

We process Identity Data, Contact Data, General Location Data, and User Content when you register and create a Nonprofit account for our Services. We process Visual Data if you upload photos.

We process this Personal Data to create and maintain your Nonprofit account, to provide the Services you request, and for our Business Purposes. We may process Identity Data and Contact Data for Commercial/Fundraising Purposes.

Fundraising Pages

We process Identity Data, Contact Data, Device/Network Data, Transaction Data, Payment Data, and User Content when you create a fundraising page associated with a Nonprofit on our Services.

We process this Personal Data to create and maintain your fundraising page, to provide the Services you request, and for our Business Purposes. We may process Identity Data and Contact Data for Commercial/Fundraising Purposes.

Become a Regional Champion

We process Identity Data, Contact Data, General Location Data, Device/Network Data, Transaction Data, and Payment Data when you become a regional champion.

We process this Personal Data in connection with your regional champion application, to add you to our regional champion directory, and for our Business Purposes.

Communications for Nonprofit Stakeholders

We process Contact Data, Identity Data, and Device/Network Data in connection with Nonprofit marketing emails, our newsletter, or similar communications, and when you open or interact with those communications. You may receive marketing communications if you consent and, in some jurisdictions, as a result of Nonprofit Profile registration or setting up a donation page on our Services.

We process this Personal Data to contact you about relevant services and for our Business Purposes. We may use this data for our Commercial/Fundraising Purposes. See "Your Rights & Choices” below to limit or opt out of this processing.


Processing Purposes

Business Purposes

We and our Service Providers process Personal Data we hold for numerous business purposes, depending on the context of collection, your Rights & Choices, and our legitimate interests. We generally process Personal Data for the following “Business Purposes.”

Service Delivery

We process Personal Data as necessary to provide our Services. For example, we process Personal Data to authenticate individual users, Nonprofit users, and their rights to access the Services, or as otherwise necessary to fulfill our contractual obligations to you, provide you with the information, features, and Services you request, and create relevant documentation.

Internal Processing and Service Improvement

We may use any Personal Data we process through our Services as necessary in connection with our legitimate interests in improving the design of our Services, understanding how our Services are used or function, for customer service purposes, for internal research, technical or feature development, to track use of our Services, quality assurance and debugging, audits, and similar purposes.

Security and Incident Detection

We may process Personal Data in connection with our legitimate interest in ensuring that our Services are secure, to identify and prevent crime, prevent fraud, verify or authenticate users, and ensure the safety of our users. Similarly, we process Personal Data on our Website as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns, and characteristics, maintain and analyze logs and process similar Personal Data in connection with our information security activities.

Personalization

We may process certain Personal Data as necessary in connection with our legitimate interest in personalizing our Services. For example, we may display a list of Nonprofits to which you have previously donated when you are signed in to your User Account. We may also personalize based on Profiles, where permitted by law, e.g. by displaying your name and other appearance or display preferences, to display content that you have interacted with in the past, or to display content that we think may be of interest to you based on your interactions with our Services and other content. 

Aggregated Data

We may process Personal Data in order to identify trends, including to create aggregated and anonymized data about donor trends, use of our Services, and other similar information (“Aggregated Data”). Aggregated Data that does not contain Personal Data is not subject to this Policy.

Google Analytics

ColoradoGives.org uses Google Analytics which is a web analytics service offered by Google (https://www.google.com) that tracks and reports website traffic.   We use Google Analytics to allow us to determine information such as the number of unique and returning visitors, how they were referred to our Website, the length of time they spend on our Website, the number of pages they visit, and other similar information.   It provides deeper insights on who is visiting the Website, and allowing us to better understand the demographics and interests of people visiting the Website. Visitors can edit their inferred demographic categories for websites or opt-out of Google Analytics Advertising Features by visiting Google Analytics' currently available opt-outs for the web. You may learn more about Google Analytics security by visiting its website.

Compliance, Health, Safety, Public Interest

We may also process Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law, for the establishment and defense of legal claims, where we must comply with requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent required or permitted under applicable law. Please see the Disclosure/Sharing of Personal Data section for more information about how we disclose Personal Data in extraordinary circumstances.

Commercial/Fundraising Purposes

Personalized Marketing Communications

We may personalize Marketing Communications based on your interactions with our Services. If consent to Marketing Communications or consumer profiling is required by law, we will seek your consent before engaging in these practices with your Personal Data.


Disclosure of Personal Data

We may disclose Personal Data to the following categories of third-party recipients and/or for the following reasons:

Nonprofits and Fundraising Page Creators – We disclose Personal Data to Nonprofits and other Fundraising Page Creators in support of our Business Purposes, and Commercial/Fundraising Purposes.   For example, we will make all information you submit to a donation page available to that Nonprofit or other Fundraising Page Creator, any Regional Champions with which the Nonprofit is associated, other third parties who we have determined have a legitimate, non-commercial interest in funds to which you may donate, and/or online fundraising reports identifying, where available, your name, address, email, any other optional data provided by you during the donation process.  We are not responsible or liable for how any Nonprofits, Regional Champions, or Fundraising Page Creators may use your Personal Data.

If you choose to make your donation and/or name hidden from the public, we will not share the amount and/or your name respectively publicly on our Website and we will communicate your desire in our reporting to the applicable Nonprofit, Regional Champion, or Fundraising Page Creator.

Colorado Gives Foundation - We may disclose your Personal Data to employees and authorized personnel within the Colorado Gives Foundation in order to streamline certain business operations, and in support of our Business Purposes, and Commercial/Fundraising Purposes.

Service Providers - We may disclose your Personal Data to Service Providers who help run ColoradoGives.org and Colorado Gives Day, collect and process donations on behalf of Nonprofits, and who provide certain services on our behalf in connection with our general business operations, including email services, payment processing, CRM, and in connection with our (or our Service Providers’) Business Purposes.

Social Media Platforms - We may disclose certain Personal Data to social media platforms in support of our Business Purposes and Commercial/Fundraising Purposes. 

Financial Partners - We disclose certain Personal Data to financial institutions to facilitate donation matching programs, such as the Incentive Fund. 

Public Disclosure - If you use any social media plugin, API, or other similar feature, use a fundraising  hashtag or similar link, or otherwise interact with us or our Services via social media, we may make your post available on our Services or to the general public. We may share, rebroadcast, or redisplay Personal Data or other information in the post to the extent permitted by the relevant social media service.

Data Aggregators - We may disclose Personal Data to data aggregators in support of our Commercial/Fundraising Purposes. These disclosures can help better personalize our Services, the services of third parties, and help ensure that you see advertisements that are more relevant to your interests.

Successors - We may disclose Personal Data if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Lawful Recipients - In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, in the vital interests of us or any person (such as where we reasonably believe the use or disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual or to public health or safety) or in such other circumstances as may be required or permitted by law. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.


Data Security

We implement and maintain commercially reasonable security measures to secure your Personal Data from unauthorized processing. While we endeavor to protect our Services and your Personal Data from unauthorized access, use, modification and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

Location of Processing

We collect and otherwise process data in the United States. If we transfer Personal Data to the United States or another jurisdiction from the European Union, United Kingdom, or another jurisdiction that regulates the transfer of Personal Data, we will make such transfers in accordance with applicable law. You can obtain more information about location data processing by contacting us.


Data Retention

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant processing purposes described in this Policy, or for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider factors including the following when we determine how long to retain data:

  • Retention periods established under applicable law;
  • Industry best practices;
  • Whether the purpose of processing is reasonably likely to justify further processing;
  • Risks to individual privacy in continued processing;
  • Applicable data protection impact assessments;
  • IT systems design considerations/limitations; and
  • The costs associated continued processing, retention, and deletion.

We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.


Children

Our Services are neither directed at nor intended for use by persons under the age of majority.  If a child under the age of 18 in the U.S. has provided us with Personal Data and if the parent or guardian of the child would like the information submitted by the child deleted from our database, we ask that a parent or guardian of the child Contact Us. If we learn that our Website has collected Personal Data from a child under the age of 18, we will take reasonable steps to promptly delete that information.


Changes to our Policy

We may change this Policy from time to time. We will post changes on this page. We will notify you of any material changes, if required, via email or notices on our Digital Services. Your continued use of our Services constitutes your acknowledgement of any revised Policy.


Your Rights & Choices

Depending on the jurisdiction in which you live, you may have certain rights and choices regarding the Personal Data we process.

Access and Portability - Right to receive a copy, in a commonly used and readily usable format, of all the specific pieces of Personal Data we have collected and maintained about you that are subject to your request, including any Personal Data held by our Service Providers in connection with our Services.

Correction - Right to correct inaccuracies in certain Personal Data that we hold about you.

Deletion - Right to delete certain Personal Data that we hold about you.

Opt-Out Rights - We do not engage in “sales” of Personal Data as defined by U.S. privacy laws, nor do we share Personal Data with third parties for them to engage in Targeted Advertising.  Accordingly, we do not include the ability for you to opt-out of these uses in our data request portal or on our Website. 

To submit a request to exercise any of these rights, contact our Data Privacy Team using the information in the “How to Contact Us/Controller Information” section above. We verify your identity in connection with most requests, as described below.

If you are dissatisfied with the decision we make or action we take (or fail to take) in response to your request, you may appeal the decision by using the contact information in the “How to Contact Us/Controller Information” section above. If you contact us to appeal, please tell us what you believe we did incorrectly in responding to your request. We will respond to your appeal in accordance with the timelines set forth in applicable law.     


Verification of Rights Requests

If you submit a request, we typically must verify your identity to ensure that you have the right to make that request, reduce fraud, and to ensure the security of Personal Data. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf. 

We may require that you match personal information we have on file in order to adequately verify your identity. If you have an account, we may require that you log into the account to submit the request as part of the verification process. We may not grant access to certain Personal Data to you if prohibited by law.


Submission of Requests

You may submit requests by contacting us as described in the “How to Contact Us/Controller Information” section, above.


Your Choices

Marketing Communications

You can withdraw your consent to receive email marketing communications by clicking on the unsubscribe link in an email, or for other communications, Contact Us by using the information above. 

Nonprofit Marketing Communications. 

When you make a donation to a Nonprofit through Colorado Gives, you consent to receive marketing communications from that Nonprofit. To withdraw your consent to receive marketing communications from a Nonprofit, please contact that Nonprofit directly.

Withdrawing Your Consent/Opt-Out

You may withdraw any consent you have provided at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you if they are conditioned on your consent or choice not to opt-out.

Cookies and Similar Technologies

General - If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You may need to opt out of third-party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.

Do-Not-Track - Our Services do not respond to your browser’s do-not-track request.

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