EFFECTIVE AS OF 08/17/2020
Changes to This Policy
We may update this Policy from time to time. If we do, we’ll let you know about any material changes, either by notifying you on the Site or by sending you an email. New versions of this Policy will never apply retroactively—we’ll tell you the exact date they go into effect. If you keep using GB after a change, that means you accept this Policy. As set out herein, the terms “you”, “your” and “users” refer to anyone who accesses the GB Site or uses GB’s Services.
Who We Are
GB, PBC (and its parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors—collectively, “GB,” “we,” or “us”) provides a platform for those who are interested in funding projects that benefit the public (our "Services"). We are a Public Benefit Corporation formed under Texas law and based in Austin, Texas.
How This Policy Applies
What We Collect and Receive
If you are an Impact Investor, we need to collect and process certain information. Depending on your use of the Services, that may include:
o Information you provide by completing forms on GB — your name, email and postal addresses, telephone number, and country of residence. We may ask for this information if you register as an Impact Investor, or upload or submit content through GB, or if you contact us;
o Information you provide for identity verification purposes when contributing to an Impact Project, including your legal name, and date of birth. In some cases, our payment processor will request that you provide a secure upload of an identity document (such as your passport, driver’s license or other government-issued ID) to GB;
o Details of any requests or transactions you make through the Services. GB partners with other companies (such as Stripe) for payment processing, and the payment information you submit is collected and used by them in accordance with their privacy policies (). GB doesn’t store your payment information apart from the last four digits of your credit card or bank account (as applicable), expiration date, and country, which we require for tax, government regulatory, and security purposes;
o Information about your activity on and interaction with GB (such as your IP address, the type of device or browser you use, and your actions on the Site);
o Information about the ways people visit and interact with our Site, in the form of traffic analytics. You can opt out of being included in . For more information about our use of data analytics to protect and improve our Services, see our “Cookies and Other Technologies”;
o Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem);
o Information that you submit on or to GB in the form of comments, contributions to discussions, or messages to other users; and
Demographic information—such as your age and gender identity —that you have the option to provide to us after giving your consent to the processing of those personal data in order to help GB equitably support all Impact Projects and represent a diverse population in our research. This category includes data that may qualify as protected classifications under other California, federal, or other applicable laws.
How We Use This Information
We use the information we collect for the following purposes:
o To keep your information secure and protect our Services (including to verify the identities of Impact Investors and Beneficiaries of Impact Projects and to prevent fraud and abuse);
o To enable us to provide you with our Services, and to improve and promote our Services;
o To contact you if necessary, and customize your experience on GB (for example, to show you projects that we think may interest you based on your previous use); and
o To track and analyze use of the Services so that we can improve how GB is performing and provide users with the best experience possible.
European Union Users
Data protection law in Europe requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Our lawful bases include:
o Collecting funds to support your designated Impact Project: Our Impact Manager may need your personal data to comply with our obligation under the Terms of Service.
o Legal compliance: Sometimes the law says we need to collect and use your data. For example, tax laws may require us to retain records of payments made through our Services.
o Legitimate interests: This is a technical term in data protection law which essentially means we have a good and fair reason to use your data and we do so in ways which do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.
For example, we may use identity, device, and location information to prevent fraud and abuse and to keep the Services secure. We may also send you promotional communications about our Services, subject to your right to control whether we do so.
We analyze how users interact with our Site so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the online experience we offer all our users.
How This Information Is Shared
Specifically, the following data will not be publicly displayed or revealed to other users:
o Any payment information you provide;
o Your password details;
o Your IP address;
o Your phone number;
o Your date of birth and other identity verification documentation (for creators);
o Private profile information, in accordance with your preferences; and
o Communications you send to us (for example, when you ask for support, send us questions or comments, or report a problem);
We may share your information with certain trusted third-party services to help us provide, improve, promote, or protect GB’s Services (like when we partner with payment processors, or use services that help us manage our ads on other sites). When we share data with third-party services that support our delivery of the GB Services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information at least to the same standards we do. We may also share information that’s aggregated and anonymized in a way that it doesn’t directly identify you.
When you back an Impact Project, the Impact Project’s Impact Manager will know your name, the amount of your Impact Investment, the reward you have selected, and any other personal information you provide when supporting the Impact Project.
We may send an Impact Investor a request for information needed to provide your reward or confirm your support. (For instance, we may need your mailing address, or T-shirt size.)
GB and its Impact Managers are required to keep backer information confidential, except as strictly necessary to communicate with backers directly and fulfill rewards. Impact Managers should not ask for personal information that isn’t necessary to provide your reward or to process your Impact Investment. Contact us at if you receive a request for information that seems inappropriate or excessive.
GB and its Impact Managers may also receive routine traffic analytics about Impact Project pages.
We reserve the right to disclose personal information when we believe that doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or abuse, or to protect GB’s legal rights, property, or the safety of GB, its Impact Managers and other employees, users, or others. This may include, in certain circumstances, disclosing information about Impact Investors to Impact Project Beneficiaries.
We will retain and use the personal information you provide as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect GB’s legal rights.
We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations.
Because GB is a US-based company, your information will be collected and processed in the United States. The United States has its own laws governing data protection and government access to information. The rules that protect your personal information under United States law may be different than in your home country. If you choose to use the Services, you need to agree to our Terms of Service, which set out the contract between GB and its users.
Users residing in certain countries, including the EU, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of your personal information. While these rights are not applicable globally, you can request a downloadable copy of your personal data from GB, and request that we delete any personal information you’ve provided to us. If you make such a request, we may retain certain information as required by law or as necessary for our legitimate business purposes.
Privacy Information for California Residents
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (all terms as defined in the California Consumer Privacy Act ("CCPA")).
Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories, and some examples of what we may collect, are:
o Identifiers and contact or registration information, e.g., your name, date of birth, email address, postal address, telephone number, country of residence, wireless device identifier, account username and password, and government-issued ID (US state-issued or the country-issued ID, passport number, etc.)
o Demographic and statistical information, e.g., gender identity, race, ethnicity, marital status, education, professional or employment-related information, interests, lifestyle information, and hobbies
o Commercial and financial information, e.g., business name; tax identification numbers; transaction history, expiration date, and last four digits of credit/debit card number; and transaction history, country of, and last four digits of bank account
o User-generated content, e.g., photos, videos, audio, any information you submit in public forums or message boards, and feedback or testimonials you provide about our Services
o Customer service information, e.g., questions and other messages you address to us directly through online forms, by email, over the phone, or by post; and summaries of your interactions with GB and its Impact Managers
o Device information and device identifiers, e.g., IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers
o Connection and usage data, e.g., information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, whether you open an email and your interaction with email content, access times, error logs, and other similar information
o Geolocation, e.g., city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, based on your mailing address
o Other Information, e.g., any other information you choose to directly provide to us in connection with your Impact Investment or use of GB’s Services
We use and share the categories of personal information we collect about you consistent with the various business purposes we discuss throughout this Policy, as described in the “How We Use This Information” and “How We Share This Information” sections above.
Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months from the effective date of this Policy.
If you are a California resident, the CCPA allows you or an authorized agent on your behalf to make certain requests about your personal information. Specifically, the CCPA allows you or your agent to request:
o Information about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Policy.
o That GB provide access to and/or a copy of certain information we hold about you.
o That GB delete certain information we have about you.
o That GB provide you with information about the financial incentives or rewards that we offer to you, if any.
Please note that certain information may be exempt from such requests under California law. For example, we may need certain information in order to provide the Services to you. We will also take reasonable steps to verify your identity before responding to a request. You are also permitted to designate an authorized agent to make certain requests on your behalf. To verify that your agent has been authorized to make a request on your behalf, we may require that your agent provide us with a signed written authorization or a copy of a valid power of attorney.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at email@example.com.
The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Email and Mobile Notifications
We want to communicate with you only if you want to hear from us. We try to keep emails to a minimum and give you the ability to opt in to any marketing communications we send.
We will send you email relating to Impact Investments you make using GB’s Services. You may also elect to receive certain marketing email communications, in accordance with your preferences, and from which you may opt out at any time. We’ll also send you service-related announcements when it’s necessary to do so.
Data Protection Authority
We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain. No method of transmission over the internet or electronic storage is completely secure, so GB cannot guarantee its absolute security. To contact our Data Protection Team, please email firstname.lastname@example.org.
Subject to applicable law, if you are a citizen or resident of the European Economic Area, you also have the right to (i) object to GB’s use of your personal information and (ii) lodge a complaint with your local data protection authority or the United Kingdom Information Commissioner’s Office, which is GB’s lead supervisory authority in the European Union.
United Kingdom Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire
SK9 5AF, United Kingdom
Telephone: +0303 123 1113
Fax: 01625 524510
People under 18 (or the legal age in your jurisdiction) are not permitted to use GB on their own. GB does not knowingly collect any personal information from children under the age of 18 and children under 18 are not permitted to use our Services.
If you believe that a child has provided us with personal information, please contact us at email@example.com. If we become aware that a child under age 18 has provided us with personally identifiable information, we’ll delete it.
Cookies and Other Technologies
What they are
Cookies are small data files that are issued to your device when you visit a website and that store information about your use of a service. Pixel tags (which are also called clear GIFs, web beacons, or pixels) are little snippets of code or tiny images embedded on websites and in email that help us learn how you interact with our site and emails.
Why we use them
How they work
When you visit GB, our web server sends a cookie to your device, which allows us to recognize your device (but not the specific person using it). By associating the identification numbers in the cookies with other account information when, for example, you log in to our Services, we know that the cookie information relates to your user account. Similarly, pixel tags on GB and in email communications help us identify how your device is being used to interact with GB content. Some of the tags and cookies used by our Services are served by us, and some are served by trusted partners who are delivering services on our behalf.
Some examples of the types of cookies and other technologies GB uses:
Some cookies help us provide localized experiences — for example, by making sure you see GB in your preferred language.
· Site features and services
Performance cookies help us route traffic between servers and understand how GB is performing, so we can provide you with the best experience possible.
· Analytics and research
· Social Media Platforms
Cookies and other technologies make interacting with social media platforms more seamless. For example, when you’re signed into social media accounts while you use our Services, these technologies enable you to share content with your social network or, in some cases, log in using your social media credentials. These features are usually controlled by the social media platform you are using and are governed by its separate privacy policies and the preferences you set with that service.
You can opt-out of online behavioral advertising. The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. To opt out of having your online behavior collected for advertising purposes, click . Certain choices you make are both browser- and device-specific.
You can control certain cookies
Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. Blocking or deleting cookies may prevent you from using most of our Services.
Our Do Not Track Policy
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
Certain options you select are browser- and device-specific.
If you have questions or suggestions, please