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Privacy Policy

PEER GIVING SOLUTIONS INC.

PRIVACY POLICY

Peer Giving Solutions Inc. and its affiliates (collectively, “Peer Giving”) is committed to protecting the privacy of its customers and employees, and the donors of Peer Giving’s customers. We value the trust of those we deal with and of the public, and we recognize that maintaining this trust requires us to be transparent and accountable in maintaining the confidentiality of the personal information that is shared with us.

Peer Giving embraces the principles of British Columbia’s Personal Information Protection Act (PIPA). We are committed to ensuring that all personal information is properly collected, used only for the purposes for which it is collected, and is disposed of in a safe and timely manner when no longer required.

1. Responsibility

We are responsible for all personal information in our possession or under our control. All employees, agents and authorized service providers of Peer Giving are required to protect the confidentiality of personal information. The information that a customer provides us, including information about their own donors, is used only for Peer Giving purposes as outlined in section 2. Our Chief Privacy Officer can be contacted at privacy@peergiving.com.

2. Purposes

We collect, use or disclose customer and donor information only for use in the following purposes:

(a) To maintain, support, troubleshoot, upgrade and improve the Charity Solutions web product licensed to our customers (and similar product offerings);

(b) To analyze, research and consider trends and developments in charitable giving;

We collect, use and disclose employee personal information for the purposes of establishing, managing and terminating employment relationships with our employees. Examples of this include:

(a) Education and employment history;

(b) References;

(c) Medical and spousal information regarding benefits;

(d) Performance reviews and evaluations;

(e) Activity logs and time reports;

(f) Vacation and sick reports; and

3. Collection

Peer Giving hosts and supports various website platforms that customers (a “Customer”) of Peer Giving license and utilize in operating the Customer’s own websites (a “Website”). The primary data relationship is between the Customer and the individual (“Donor”) visiting the Customer’s Website.

As part of Peer Giving services, the Customer shares with Peer Giving certain Donor personal information. The Donor information indirectly collected by Peer Giving in this fashion is only used by Peer Giving for the purposes outlined in Section 2.

Peer Giving relies on its Customer to ensure compliance with all applicable law relating to Peer Giving’s collection, use and disclosure of Donor information.

Peer Giving also directly and indirectly collects information about its own employees and occasionally (but rarely) collects information about other individuals on the Peer Giving website.

4. Visitors to Peer Giving Website

Like most website operators, Peer Giving collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Peer Giving’s purpose in collecting non-personally identifying information is to better understand how Peer Giving’s visitors use its website. From time to time, Peer Giving may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.

Peer Giving also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users. Peer Giving only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below.

5. Consent

If we collect, use or disclose Donor personal information other than as set out above we will only do so with Donor permission. The way we seek consent may vary depending on the sensitivity of the information and the reasonable expectations of the individual. Permission may be expressed in writing or it may be implied and may be given verbally or electronically.

6. Mailing List

Peer Giving maintains an opt-in mailing list. A Donor always has the opportunity to decline receiving further communication from us by contacting support@peergiving.com.

We will obtain individual Donor consent before making contents of our mailing list information available to third parties.

7. We Will Limit Collection

We will limit the amount and type of personal information collected to that which is necessary for our identified purposes.

8. We Will Limit Use, Disclosure and Retention

We will keep personal information only as long as it is necessary to satisfy the purposes for which it was obtained or as required by law or standard business practice. Where personal information is no longer required to fulfill the identified purposes, it will be destroyed, erased, or made anonymous.

9. Accuracy

We will use our best efforts to ensure that personal information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. An individual is entitled to seek a correction of personal information if they believe that the information in our possession is not correct.

10. Safeguard

We will protect personal information with safeguards appropriate to the sensitivity of the information. Our safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held.

11. We Will Be Open About Our Privacy Practices

We will make readily available relevant information about our policies and practices relating to the management of personal information.

12. Access

Upon written request, we will inform an individual of the existence, use, and disclosure of their personal information in the control of Peer Giving and we will provide access to that personal information. We will respond to an individual’s written request within a reasonable time (generally within 30 days).

13. Complaints

An individual may register a privacy-related complaint by contacting privacy@peergiving.com. We will explain our procedure and provide information about other complaint procedures available. If we find a complaint to be justified, we will take all appropriate measures, including if necessary, amending our policies and practices.

14. Protection Information

Peer Giving discloses personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Peer Giving’s behalf or to provide services available at Peer Giving’s website, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of Canada; by using Peer Giving’s websites, a visitor consents to the transfer of such information to them. Peer Giving will not rent or sell personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Peer Giving discloses personally-identifying information only in response to a subpoena, court order or other governmental request, or when otherwise required or permitted by applicable law. If a registered user of a Peer Giving website supplied an email address, Peer Giving may occasionally send an email about new features, solicit feedback, or inform about developments at Peer Giving.

Last updated: 11 July 2012