Privacy Policy – December 2022 version

We have published a more recent version of this page. See our most recent version of this page.

Effective Date: May 15, 2018; last updated: December 5, 2022 (November 2020 version; May 2020 version)

Changes since last update

We made several clarifications in the December 2022 version of this Privacy Policy ("Privacy Policy"). We provided additional information about the service providers that we use. We have also added language to accommodate recent changes in applicable privacy laws. If you'd like to see the previous version of our policy, it is available here.

The Clear Fund aka GiveWell ("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 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.

Table of Contents

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 personally identifiable 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 about our donors from third-party sources to personalize communications with donors and improve donor retention. We check in with donors throughout the 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 promotional efforts, to analyze website usage, to improve our website's content, layout, security, and services, as otherwise reasonably necessary for our internal administrative purposes, and/or as otherwise permitted by applicable law.

GiveWell employs vendors to assist us with such functions as hosting our donor information database, sending email, modeling our data, promoting GiveWell to donors and new audiences, and processing online and mail donations and credit card payments. In addition, GiveWell consults advisors in making organizational decisions and developing long-term plans for our organization. These companies and advisors have access to the following types of donor personally identifiable information, in each case to the extent needed to perform their functions: name, address, telephone number, and email address. Additionally, vendors that we have retained to process payments from donors will receive your credit card information to enable them to secure, validate, and otherwise process any donations that you make to us. GiveWell requires that all vendors and advisors 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 provide any of your personal information to third parties for profiling or targeted advertising purposes. We do not sell, rent, or give donor personally identifiable 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 that we have created regarding donations made to us, but these statistics do not include any of your personally identifying information. The information given includes, for example, total number of donors and total amount of donations within specific periods of time.
Except for the purposes and in the manner described in this Privacy Policy, we will not share or provide access to donor personally identifiable information without first obtaining donor consent.

Other information submitted

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 for our promotional efforts, to analyze website usage, and to 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. GiveWell requires that these third parties 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.) If you’d like to opt out of receiving newsletters or other communications from us, you can follow the unsubscribe instructions in the materials or contact us at privacy@givewell.org.

Except for the purposes and in the manner described in this Privacy Policy, we will not share or provide access to personally identifiable information provided to us without first obtaining your consent.

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, email 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 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

In addition to the purposes that we have described above, please be advised that we may also disclose your personal information, as required by law, to federal, state, local, other governmental authorities, or law enforcement agencies, or to third parties pursuant to law enforcement inquiries, court orders, subpoenas, and similar lawful demands or legal processes. In addition, we may disclose your personal information with or without a formal subpoena where permitted by law if we believe in good faith that such disclosure is necessary or appropriate (a) to meet our obligations under applicable laws, rules, or regulations, (b) in the event of a legal dispute (whether actual or anticipated), (c) to preserve the integrity or security of our systems, which may include actions taken to prevent, detect, protect against or respond to security incidents, identity theft, fraud, harassment, or malicious, deceptive, or illegal activity, (d) to protect the vital interests of any person, or (e) to otherwise protect the 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 (such as commenting on our blog) may allow you to elect to share information publicly, 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 confirm their compliance with the Payment Card Industry Data Security Standard (PCI-DSS), and otherwise provide services to us in a manner that is consistent with the prevailing practices and standards applicable to their industry. 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 by vendors assisting with certain functions. We employ industry-standard techniques such as firewalls, encryption, intrusion detection, and site monitoring to protect your personal 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 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 information or adjust your mail preferences, you can do so by contacting us at privacy@givewell.org. We will respond to your request in accordance with applicable law.

If you’d like to opt out of receiving newsletters or other communications from us, you can unsubscribe at any time by following the unsubscribe instructions in the materials, or (in the case of our promotional e-mails) using the link provided at the bottom of any e-mail, or contacting us directly at privacy@givewell.org.

Note that you may continue to receive communications from us even if you elect to stop receiving our newsletters. For example, if you make a donation to GiveWell after you have unsubscribed, an e-mail will be sent to you to confirm receipt.

Website visitor information

You can browse the GiveWell website without telling us who you are or revealing any personally identifiable information about yourself. The information we gather during browsing comes from three sources. First, standard server logs collect information such as the IP (Internet Protocol) address, domain name, browser type, operating system, 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, emails, or other outreach communications, or from a site that has requested a special link to us, we may track the information provided in that link, in order to help us match referring sites to donations made. Third, some information is gathered by cookies. We may use such information to evaluate the success of our promotional efforts, to analyze website usage, to improve our website's content, layout, security, and services, as reasonably necessary for our internal administrative purposes, and as otherwise permitted by applicable law.

Cookies and similar technologies

We use cookies and similar tracking technologies, such as pixels and web beacons (collectively referred to as cookies), 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 cookies for our website’s functionality and to expand functionality, 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 and our promotional materials.

GiveWell uses the following types of cookies:

Strictly Necessary

These cookies enable necessary website functionality such as donation forms, surveys, the comment feature on our blog, and other interactive features on our sites. This type of cookie also remembers users' preferences, such as for a font size.

Analytics

These cookies track information about how users interact with our site, such as the pages they view, how much time they spend on the site, whether or not they found our site via a link on another website, and whether they are a new or returning visitor to our site.

If you prefer, you can usually set your browser to refuse cookies, or to notify you when you receive a new cookie.

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 personally identifiable 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 (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, they 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 pursuant to the Shine the Light Law, which we will provide to you free of charge:

  1. A list of the types of personal information which we disclosed to third parties for direct marketing purposes in the preceding calendar year (note that there is only one case in which we divulge such information: if you allocate your donation specifically to a recommended charity, we share the contact information for those 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 received personal information from us in the preceding calendar year for direct marketing purposes.

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, but maintains a sister organization called “GiveWell UK” in the United Kingdom. Personal data processed by GiveWell U.K. is subject to the GiveWell U.K. privacy policy, which is available here. Regardless of where you are located, we collect and use personal information as described above, including donor, website visitor, and other information, 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. Additionally, our website may be accessed and you may submit your personal information to us regardless of where you are located.

For visitors to the GiveWell website who are subject to any one of (i) the General Data Protection Regulation, (ii) data protection laws implemented by member states of the EU in harmony with the General Data Protection Regulation, or (iii) the UK Data Protection Act of 2018, as amended and incorporated into UK law (collectively, the “GDPR”), the terms of this section will govern how we process your personal data. In the event of any inconsistency or conflict between any term of this section and the rest of our Privacy Policy, the terms of this section will control as required by law.

For consistency’s sake, all references to the term “personal data” in this section should be read to have the meaning applicable under the GDPR.

  1. Lawful Grounds. We rely on either your consent or our legitimate interests as described in this Privacy Policy for the collection and use of your personal data. We use, retain, and otherwise process personal data for as long as necessary to accomplish the purposes for which the data was collected, such as to perform a contract, for our legitimate interests, or as otherwise permitted with your consent. The purposes for which we collect personal data are fully set forth in this Privacy Policy.

    If we are processing your personal data based upon your consent, you have the right to withdraw your consent for such processing at any time without affecting the lawfulness of processing based on consent before it is withdrawn. To withdraw consent, email us at privacy@givewell.org.

  2. Data Transfer. We use servers located in the United States to process your Personal data. By accessing the GiveWell website, you explicitly consent to the transfer of your Personal data for processing in the United States.
  3. Rights. You may exercise any rights available to you under the GDPR by writing to us at privacy@givewell.org. Your rights under the GDPR include the right to request access to, transfer of, and rectification or erasure of your personal data; under certain circumstances, you may also have the right to restrict the processing of, or request the deletion of, any personal data that we have processed about you. Additionally, you may request information about how we process your personal data and your rights under the GDPR.

    Any requests that you submit to exercise your rights under the GDPR must specify the nature of your request and the information that is the subject of your request. We may require you to submit additional information necessary to verify your identity and status as an EU data subject. If you are a visitor to the GiveWell website, we will respond to your request directly within 30 days. Note that if you request that we delete your personal data, we may nevertheless retain certain personal data about you once we have completed your request for purposes of keeping a record of our compliance and as otherwise permitted by law.

  4. Retention. At a minimum, we will retain your personal data for as long as necessary for the purpose in which it was collected such as to perform a contract, for our or a third-party’s legitimate interest, or your consent.

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

Updates to this Privacy Policy

We may, from time to time, update our Privacy Policy, based on your comments and our need to reflect accurately our information collection and disclosure practices. Updates apply to all information we hold. If we make any material changes in the way we collect or use your personally identifiable information (for example, a significant or material change regarding the categories of personally identifiable information we collect, the ways we use such information, or with whom and how we share such information), we will notify you of those changes using such methods as updating our Privacy Policy or notifying you by email.

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 December 5, 2022. GIVEWELL® and other marks used on this website are trademarks of GiveWell.


Source URL: https://www.givewell.org/about/official-records/privacy-policy/December-2022-version