In addition to cookies, we may use other technologies, including single-pixel gifs (also known as web beacons) on Benevity Sites and in email messages or newsletters. These tiny electronic images assist us in determining how many users have visited certain pages or opened messages or newsletters. We do not currently use these images or beacons to collect Personal Information, and we will tell you by way of amendment of this policy if we do.
Consent to Collection of Personal Information
The Personal Information provided by our corporate clients to initiate workplace programs is to establish the employee’s eligibility and log-in credentials, to implement payroll giving, if applicable, and provide reporting to our clients based on office location and business units.
Use of Your Personal Information
Where applicable based upon your usage of a particular Benevity Site, we may collect and use your Personal Information to:
- create and manage your user account;
- process and report upon your donation, volunteering, charitable gift card, prosocial activities or other transactions;
- provide client service and related assistance to you or the corporate client of the Benevity Site;
- perform research and analysis aimed at improving the Services, the Benevity Platform and the philanthropic landscape;
- display or provide content that is created by you or customized to your interests and preferences;
- operate interactive areas of the relevant Benevity Site;
- if you are a contributor to any of the third-party donor advised foundations that form part of the Benevity Platform, facilitate your donation transactions and prepare tax information slips or other acknowledgments;
- interact with our client that has licensed the Site for its employees and other users;
- if you are a contributor to a news or information forum feature or a user-generated or team fundraising or volunteering event within one of the Benevity Sites, identify your uploaded content as your content;
- communicate with you about your donation and volunteering transactions, your use of the Services, and new products and services; and
- carry out other purposes which are disclosed to you and to which you consent or are permitted or required by applicable law.
Correcting and Updating Your Personal Information
Users participating in relevant workplace programs may update or change their registration information by editing their user or organization record on the relevant Benevity Site. To update a user profile, please log in to the relevant Benevity Site with your username and password and click on your name in the header or “User Profile” in the footer. Once in the user profile, edit by clicking on “Tax Receipt Information” to update any of your Personal Information. To discontinue your account, please contact your employer in the case of a Spark! Site, the corporate host of any other Benevity Site, or email email@example.com. Any user may request to access or correct their Personal Information by contacting us at firstname.lastname@example.org. We will respond to requests to access, change or delete such information within 30 days and may be under an obligation to share such request with the corporate host of the Benevity Site.
Retention and Destruction/Anonymization of Personal Information
We retain Personal Information we collect from you in accordance with applicable law and where we have an ongoing legitimate business need to do so (for example, to provide you with a service you or your employer have requested or to comply with applicable legal, tax or accounting requirements). Canadian law allows us, for legal or business purposes, to retain Personal Information for as long as is reasonable (typically seven years from the deactivation of a user account). Upon expiry of an appropriate retention period, bearing in mind reasonable legal and business requirements, Personal Information will either be destroyed in a secure manner or made anonymous.
Personal Information Preferences
In addition to you controlling the marketing and survey information that may be sent to you as described previously in this Policy, we offer users who provide contact or other Personal Information a means to choose how we use the information you provide. You may manage your receipt of non-transactional communications and whether we share your contact information and donation data with the causes to which you donate your time or money by selecting or unselecting the appropriate box in your user profile or the donation forms that are part of the relevant Benevity Site. Additionally, you may send a request specifying your communications preferences to email@example.com.
Rights of European Economic Area (“EEA”) and California Residents
In addition, if you are a resident of the EEA or California, you have the following data protection rights, as applicable under relevant data protection laws:
a) If you wish to access, correct, update or request deletion, in the form of anonymization, of your Personal Information, you can do so at any time by contacting us using the contact details provided below;
b) You can also object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details below;
c) Where in the case of a workplace program, we derive the custody or control of the Personal Information through our corporate client, the client will be the controller and all requests for access to Personal Information should be forwarded through such controller to us;
d) Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent;
e) You have the right to complain to the relevant regulator about our collection and use of your Personal Information. For more information, please contact your relevant regulator.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Our legal basis for collecting and using the Personal Information provided by our clients to initiate workplace programs is a legitimate interests basis. Any information provided by any user in any other context is on a consent basis, or to perform a contract with you.
For California residents, pursuant to the California Consumer Privacy Act (“CCPA”), the above applies to the Personal Information collected during the 12-month period prior to the date of the request.
For clarity, Benevity does not sell Personal Information.
International Data Transfers
Personal Information collected by us may be stored and processed in Canada, the United States or any other country in which we or our agents maintain facilities, and by providing us with your Personal Information and using any of the Benevity Sites or Services, you consent to any such transfer of information outside of your country (if however, you are using the Benevity Sites as an employee pursuant to a workplace program, Benevity should be considered a “data processor” under applicable privacy laws, and your employer is the “data controller” who has provided such consent). As a result, this Personal Information may be subject to access requests from the corporate employer, governments, courts or law enforcement officials in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in such other jurisdictions, we will ensure that appropriate protections are in place regarding all Personal Information.
Benevity International, Inc. is subject to the investigation and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, in addition to your relevant regulator, you may also contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Whether you’re a new or loyal user of our Services, a cause, or another user of a Benevity Site, we’d like to stay connected and want to hear from you! We are constantly striving to improve the Services and Make Goodness Better. Let us know if you have any ideas, suggestions or issues.
Benevity, Inc., 700, 611 Meredith Road NE, Calgary, AB T2E 2W5 Email: firstname.lastname@example.org
Last Revision: February 20, 2020