Privacy Policy - May 2020 Version

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Effective Date: May 15, 2018; Updated May 2020

GiveWell aka The Clear Fund ("GiveWell") is strongly committed to protecting the privacy of our donors, website visitors and other individuals who communicate with GiveWell. We wish to help you better understand the information we gather, how we handle it, whether we disclose it to anyone, and your options regarding this information. This Privacy Policy applies when you make a donation to GiveWell, either online or otherwise, as well as when you visit our site www.givewell.org, or otherwise share your personal information with GiveWell as discussed below. By visiting our website, you are accepting this Privacy Policy. We will also provide hard copies of our Privacy Policy upon request.

Collection and use of personal information

Donor information

If you make a donation, either online or otherwise, we will request certain personally identifiable information about you (such as your name, address, telephone number, email address, and credit card information). We use this information to process your donation and communicate with you about it. We also receive personal information from partner organizations when you make a donation through them and elect to share your information with us. We also use publicly available information from third party sources about our donors to personalize communications with donors and improve donor retention. We check in with donors, no more than a few times a year, about whether you are interested in donating again. In addition, we may use this information to keep you updated about our work if you explicitly indicate that you would like us to do so. You can choose to stop receiving check-in and update information by following the unsubscribe instructions included in the materials or by contacting us at privacy@givewell.org. We may use such information to evaluate the success of our marketing and promotional efforts, analyze website usage, and improve our website's content, layout, and services.

GiveWell employs vendors to assist us with such functions as hosting our donor information database, sending e-mail, modeling our data, marketing and promoting GiveWell to new and existing donors, and processing online and mail donations and credit card payments. In addition, GiveWell consults advisors in making organizational decisions and developing long term plans. These companies and advisors have access to personal donor information as needed to perform their functions. GiveWell requires that they keep such information confidential and that they not use such information for purposes other than the functions they are assisting us with. (See Security section below.)

We do not sell, rent, or give personal donor information to any other party not under the employ of, or in a direct advisory or vendorship role to, GiveWell with one exception: if you give us permission to share your name, contact information, and details of your donation with one or more of our recommended charities. We will not share your information with these organizations unless you explicitly give us permission to do so.

We may disclose to third parties aggregate statistics regarding donations but these statistics do not include any personally identifying information. The information given includes total number of donors and total amount of donations for specific periods of time.

Other information you submit

Through our site or otherwise, you may decide to submit personally identifiable information (such as your name, postal address and email address) for purposes other than donating (such as receiving an email newsletter or further information as to a particular topic, or commenting on our blog). We collect and store this information and use it for the purposes for which you submitted it.

We may use such information to evaluate the success of our marketing and promotional efforts, analyze website usage, and improve our website's content, layout, and services. We do not share this information with any third parties except those that assist us with certain functions, as described above. You can change the purposes for which you submitted information by following the unsubscribe instructions included in communications with you or by contacting us at privacy@givewell.org.

Employment

In connection with seeking employment or a volunteer position with GiveWell, you may decide to submit, through our sites or otherwise, personally identifiable information (including your name, address, telephone number, e-mail address and any other personally identifiable information requested on our online and offline forms, as well as an electronic or paper copy of your resume/CV). All information entered into any online or offline forms related to employment or volunteering is strictly private, and will be viewed only for human resources purposes by GiveWell and third parties that assist us with certain functions (see above). This information may be used to assess your qualifications as an employee or volunteer for GiveWell, or to analyze general patterns in applications for positions or hiring at GiveWell.

Other disclosures

Please be advised that we may disclose your personal information, as required by law, to the government or to third parties pursuant to law enforcement inquiries, court orders, subpoenas and similar lawful demand or legal process. In addition, we may disclose your personal information with or without a formal subpoena if we believe in good faith that such disclosure is necessary or appropriate (a) in connection with any activity that violates the law, (b) in the event of a legal dispute, (c) to prevent or stop activity we believe may pose a risk of being illegal, unethical, or may expose us to liability, or (d) to protect the safety of the public or any person, or rights of GiveWell. In addition, we may sell, assign, transfer or otherwise share some or all of our assets, including your personal information, in connection with a business transfer such as a merger, acquisition, sale of assets, or reorganization, or in the event of bankruptcy.

Some features of our website may allow you to elect to share information publicly (such as commenting on our blog), in which case we would make such information available in accordance with the options you elect.

Security

We require that the vendors we work with to process your online donation payments use industry-standard encryption and security protocols, and that all vendors processing check and credit card transactions received on our behalf meet all industry standards, certify their compliance with the Payment Card Industry Data Security Standard (PCI DSS), and are audited to meet with the Statement on Auditing Standard 70 (SAS 70). We follow commercially reasonable administrative, technical and physical safeguards to protect personal information against accidental or unlawful destruction or loss, or unauthorized disclosure, access or use. The personal information that you provide is stored in a secure location and accessible only by designated employees trained in the proper handling of personal information or vendors assisting with certain functions. We employ industry standard techniques such as firewalls, encryption, intrusion detection, and site monitoring to protect your personally identifiable information from unauthorized access by users inside and outside the organization. You should be aware, however, that "perfect security" does not exist on the Internet or in any method of storage; third parties may unlawfully intercept or access transmissions or stored information. If we learn of a security breach involving your personal information, we will inform you of the occurrence of the breach in accordance with applicable law.

Updating your information

We work to process and maintain accurately the information that you share with us. If you have donated to us or shared personal information with us and would like to correct or update your personal data or to adjust your mail preferences, you can do so by contacting us at privacy@givewell.org. You may also send requests to remove or limit our use of your personal information to privacy@givewell.org.

We provide a link to unsubscribe from each of our mailing lists in each email from that list.

Website visitor information

You can browse the GiveWell sites without telling us who you are or revealing any information about yourself. The information we gather during normal browsing comes from two sources: first, standard server logs collect information such as the IP (Internet Protocol) address, domain name, browser type, operating system, and information such as the site that referred you to us, the files you downloaded, the pages you visited, and the dates/times of those visits.

Second, if you have come into the site from one of our newsletters or from a site that has requested a link to us, we may ask your browser to accept a cookie that carries a general marketing source code with you as you browse through the site, in order to help us match referring sites to donations made. This cookie does not capture or hold any personally identifying information about you, and is deleted when you end your session by leaving our site or closing your browser.

Cookies and similar technologies

We use cookies and similar tracking technologies such as pixels and web beacons, such as from Clicky and Google Analytics, when you visit our website or make an online donation. We might store some information on your computer in the form of a “cookie” (i.e. a small piece of text that stores information on your browser in your computer’s hard drive) or similar file (pixel or web beacon). We use these tracking devices to analyze trends, gather broad demographic information, and monitor site traffic patterns that can help us further develop and improve the design and functionality of our site. We may maintain the information for these purposes.

If you prefer, you can usually set your browser to refuse cookies, or to notify you when you receive a new cookie. You can also opt out of receiving cookies on the GiveWell website for Google advertising by visiting the Google advertising opt-out page (https://www.google.com/policies/technologies/ads/).

External links

Our site contains links to other sites. GiveWell is not responsible for the privacy practices of other sites.

Special notes on privacy laws

Note to parents and children

Our site is not intended for use by children under the age of 16. GiveWell welcomes children to learn more about our organization and about issues presented on the GiveWell sites, and we are particularly respectful of the privacy of our young users. We encourage parents to monitor their children's use of the Internet and to help us protect their privacy by instructing them never to provide personal information on this site or any other without permission. We will never attempt to extract unnecessary information from our users, regardless of age. Consistent with the Children's Online Privacy Protection Act of 1998 ("COPPA") and the European Union General Data Protection Regulation(“GDPR”)(Regulation (EU) 2016/679), we will never knowingly request personally identifiable information from anyone under the age of 16 without prior verifiable parental consent. If we become aware that a child under 16 has provided us with such information without consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that a child under 16 has provided such information to us, he or she should contact us at privacy@givewell.org.

Your California privacy rights

If you are a resident of California, you are entitled to request the following information, which we will provide to you free of charge:

1. A list of the types of personal information which we disclose to third-parties for direct marketing purposes in the preceding calendar year (note that the only case in which we divulge such information is in sharing contact info for donations with our recommended charities in cases where you've given explicit permission for us to do so); and
2. The names and addresses of all third parties that receive personal information in these categories from us in the preceding calendar year, and examples of the products or services marketed by these businesses: (a) name and address; (b) electronic mail address; (c) age or date of birth; (d) names of children; (e) electronic mail address of children; (f) number of children; (g) the age or gender of children; (h) height; (i) weight; (j) race; (k) religion; (l) occupation; (m) telephone number; (n) education; (o) political party affiliation; (p) medical condition; (q) drugs, therapies, or medical products or equipment used; (r) kind of product purchased, leased or rented by customer; (s) real property purchased, leased or rented; (t) the kind of service provided; (u) social security number; (v) bank account number; (w) credit card or debit card number; (x) payment history; and (y) information pertaining to assets, liabilities or credit worthiness.

Please direct your request for these types of information to privacy@givewell.org.

Note on the EU's General Data Protection Regulation

GiveWell is located in the United States. Regardless of where you are located, we collect and use personal information as described above for the purposes described above. In particular, we receive personal information regarding donors located in the European Union from partner organizations located in the European Union when you make a donation through them and elect to share your information with us. We rely on either your consent or our legitimate interests as described above for the collection and use of such personal information. We retain personal information regarding donors for as long as necessary for our legitimate interests. If you have any questions or concerns, or would like to make any requests regarding your personal information, please contact us at privacy@givewell.org.

Your interaction with this privacy policy

Changes to this privacy policy

We may, from time to time, make changes to our Privacy Policy, based on your comments and our need to reflect accurately our data collection and disclosure practices. If we make any substantial changes in the way we collect or use your personal information, we will notify you by posting an announcement on our website.

Questions or suggestions

It is important to us at GiveWell to hear what our site visitors and donors have to say about our services or our policies. If you have any questions, concerns, or complaints about this Privacy Policy, or want to let us know what you think about our products and services, please contact us at privacy@givewell.org.

Governing law

You agree that your use of our site and this Privacy Policy and any disputes relating thereto shall be governed in all respects by the laws of the State of California. Any dispute relating to this Privacy Policy shall be resolved solely in the state or federal courts located in San Francisco, California.

This Privacy Policy was last updated on May 15, 2018. GIVEWELL® and other marks used on this website are trademarks of GiveWell.