1. Our Commitment to Privacy

Benevolence, Inc., which has developed a proprietary crowdfunding platform called Fund My Charity that allows users to raise charitable donations (“Fund My Charity”, “we”, or “us), is committed to respecting and protecting your privacy. Fund My Charity has developed this Privacy Policy (“Privacy Policy”) to help make sure you understand what information we collect and what Fund My Charity does with the information we collect. The Privacy Policy discloses the information we gather on www.fundmycharity.com (the “Site”), as well as the ways in which we process and share such information and how you can correct or change such information. This Privacy Policy addresses our privacy practices relating to the general use of our Site by anyone who visits, browses or otherwise uses the Site, or who otherwise contacts us by mail, email, social media or telephone in connection with the services we offer (collectively, “you”).

By visiting the Site, submitting information, making a donation or using any of our products or services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and/or processed in the United States. If you do not agree to this Privacy Policy, please do not use the Site.

2. The Information We Collect

Fund My Charity is a crowd-funding platform for people and organizations to raise support for charitable causes.

We collect the following categories of information from you:

A. Information Provided by Individuals

We may receive and store any information you enter on the Site or provide to us in any other way that would allow us to identify you or contact you. Examples of information we may collect from you include:

• If you set up a personal account, we collect your name, email address and may ask you for your birthday and, if you choose, social information (from the social networking site you connected with), your sex, any photos that you upload to the Site, your mailing address and phone number;

• Your email address and any information you provide to us when you email us, or Contact Us, or when you post on the Site;

• Information you provide about yourself on your account page, a project page or anywhere else on the Site. For example, if you use any third-party platforms, such as Facebook or Twitter, to share information about yourself on the Site, we collect that information; or

• If you enter a sweepstakes, we collect your name, address and contact information to administer the sweepstakes and fulfill prizes and, to the extent permitted by law, to provide you with information on upcoming events, announcements, and sweepstakes.

If you do not want us to collect information about you, you can simply decide not to submit it to us. If you choose to decline to submit such information, you may not be able to take advantage of all of the services and products offered on the Site.

B. Information Collected From Charities

If you are a charity or nonprofit (each a “Charity”) and you establish an account with Fund My Charity, we will collect the name, tax ID, physical address, email address, birthday and phone number of the person who establishes a Charity account and claims your Charity (the “Charity Contact”) and any other information that is provided to us by GuideStar about your Charity. We also may collect, if the Charity Contact chooses to provide it, the Charity Contact’s sex, or any photos uploaded to the Site.

C. Passive Gathering of Information Electronically

1. Cookies

When you interact with the Site, we try to make that experience simple and meaningful. When you visit our Site, our web server sends a cookie to your computer or mobile device (as the case may be). Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application, and which store and sometimes track information about your use of the Site (as the case may be). A number of cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to the Site and will last for longer.

Some of the cookies used by the Site are set by us, and some are set by third parties who are delivering services on our behalf.

Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers or mobile devices. Please note, however, that by blocking or deleting cookies used on the Platform, you may not be able to take full advantage of the Site.

2. Web Beacons

A web beacon is a transparent image file. Web beacons enable Fund My Charity to track website usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer. We may use them in association with cookies to understand how visitors interact with the pages and content on the pages of the Site.

We may also use Web beacons to track whether you have opened an HTML email. When the email is opened, a part of the code that makes up the HTML page calls a web server to load the web beacon that then generates a record showing that the email has been viewed. Web Beacons may also recognize when the email was opened, how many times it was forwarded and which URL’s (links within the email) were clicked.

3. Pixel Tags

In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to information that is intended to identify our users.

D. Aggregated and De-Identified Information

From time to time, we may also ask you to provide us information that is not intended to allow us to identify you personally. This information may be aggregated and/or de-identified and used for our internal purposes or for creating reports for third-party advertisers and partners, or otherwise shared with third parties for any lawful purpose, without your permission.

We also may automatically collect Site usage information, such as the numbers and frequency of users to the Site, pages visited and similar data. This data is used in the aggregate and/or is de-identified, that is, as a statistical measure, and not in a manner that is intended to identify you personally. Aggregate and de-identified information generally is collected through the use of cookies and web beacons as discussed above, but we may also aggregate or de-identify data that you provide to us. This aggregate and/or de-identified information helps Fund My Charity determine general usage patterns and modify the Site in order to improve your experience. This type of aggregate information may be shared with third parties at any time.

E. Information from Third Parties

It may be necessary for us to obtain address or other information about you from third-party sources for fraud prevention or for legal compliance, to enforce our legal rights or to protect the rights of other users of the Site and our services.

3. How We Use Information

When you provide us with your information, we may use such information for a number of purposes, including:

• To facilitate communication between Fund My Charity and you including, without limitation, responding to your questions or comments, sending emails concerning our products and services including upcoming events, announcements, and sweepstakes, or to contact you for feedback regarding us, advertisers or business partners;

• To administer your account, process donations, provide products or services to you and for Fund My Charity marketing and promotional activities;

• To provide a report to a Charity or an event supporting a Charity to whom you have made a donation or to a fundraiser to whom you have made a donation, supported a project or joined a team (even if you have marked the donation as non-public);

• To provide a report to a partner or campaign organizer who is helping promote a Charity or an event supporting a Charity to whom you have made a donation, including your name, email address, or other similar information;

• To provide a report to our advertisers or business partners that tells them who responded to a particular offer or to facilitate the fulfillment of an order that you have made with an advertiser or business partner;

• To provide our gift registry partners with all the necessary data to accurately update their gift registries, including data related to the establishment of a donation registry and the applicable Charities, the Fund My Charity Fundraiser(s) that established the donation registry, the applicable Event, the donors to such donations registry and the details of each donation;

• To provide you with important functionality changes to the Site, new Fund My Charity services and, to the extent permitted by law, special offers from Fund My Charity and reputable third parties that we think you will find valuable;

• To customize, analyze, adjust and improve the Site to meet our, advertisers’ or business partners’ needs and expectations;

• To enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws;

• To send emails to friends based on your instructions as discussed in E-mail Communications to You and Your Friends; or

• To associate users’ activities, customize content, or tailor advertising to those users across different devices and browsers (for instance, tablets, mobile devices and applications, and websites).

4. Analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Cookies and other electronic technologies” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive, and provide certain features to you. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. This information may be used to place interest-based advertisements on the Platform. This may result in you seeing advertisements for our Platform when you visit other websites. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

5. Tailored Advertising

We may use third-party advertising technologies that allow for the delivery of relevant content and advertising on our Platform, as well as on other websites you visit. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

Also, third parties whose products or services are accessible or advertised on our Platform may place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the website as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on our website, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the website. We may provide our customer information (such as a hashed version of your email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to target or “retarget” you with ads when you visit other websites and mobile applications. (You may opt out of these many of these service providers as described in the next paragraph.)

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access our website by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below.

If you receive tailored advertising on your computer through a web browser, you can learn more about such tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, by visiting the European Interactive Digital Advertising Alliance Consumer Ad Choices link for EU based advertising or for US based advertising either: (i) the Network Advertising Initiative’s Consumer Opt-Out link or (ii) the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.

Please note that to the extent advertising technology is integrated into our website or other websites that you visit, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

6. How We Respond to Do Not Track Signals

We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site.

7. E-mail Communications to You and Your Friends

When you send an email to Fund My Charity, we may retain your email address and the contents of the email you send.

When you use the email share button, a service provided to us by Gigya, Inc., you are agreeing to the Gigya Terms of Use and Privacy Policy.

8. Accessing or Changing Your Information

Fund My Charity allows you to change or correct inaccuracies in some of your information by logging into your account and making changes at any time. If you have questions about, or wish to review or correct the information we maintain about you, you may send an email to [email protected] or through the Contact Us feature.

9. Disclosure of Information to Third Parties

Fund My Charity may give, share, sell or trade your information to or with any third parties under the following circumstances:

A. Charities, Event Organizers, Event Partners, Sweepstakes Partners & Gift Registry Partners

When you make a donation or sign up to, volunteer, fundraise, enter a sweepstakes, or register for an event for a Charity or for an organization or event associated with fundraising (e.g., a marathon, walkathon, concert or similar), Fund My Charity shares with the Fundraiser, Charity, Event Organizer, Sweepstakes Partners and Event Partners your name, address, email address, donation amount, date of transaction, transaction identification number and may also include the name of the project, and event associated with the donation. This information may be used by the Charity to facilitate your participation in an event, to accept and process your donation, or to contact you as otherwise permitted by law. If you wish to stop receiving communications from a Charity, Event Organizer, Sweepstakes Partners, or Event Partner, please contact the Charity or Event Organizer or Event Partner directly.

Also, if you establish a donation registry, Fund My Charity shares with any gift registry partners all of the details related to the donation registry sufficient to allow users of the gift registry partner to search for the donation registry, which will include your full name and email address, any co-registrant’s full name and email address, event date, event State/Provinces, event type, unique registry ID and the applicable Charities. Also, if you make a donation to a Fund My Charity donation registry, Fund My Charity shares with any gift registry partners (e.g. The Knot, The Bump) all of the details related to the donation including your full name, email and mailing address, date of donation and amount of donation. Fund My Charity will continuously provide this information to its gift registry partners to allow the gift registry partners to accurately update their gift registries. If you wish to stop receiving communications from a gift registry partner, please contact the gift registry partner directly.

Also, if you enter a sweepstakes on Fund My Charity, you agree that we may share your name, address, email address, donation amount, date of transaction, transaction identification number and may also include the name of the project, and event associated with the donation with the charity we designate as the benefiting charity for such sweepstakes and with any entity providing prizes for that sweepstakes, who may use your information for marketing purposes to the full extent permitted by law. If you consent, or as otherwise permitted by law, we may also use the information that you provide to us to communicate with you about our current activities, future activities, and sweepstakes or to notify you about any changes to our services. If you decide that you would no longer like to receive such messages you can opt-out from receiving such emails from Fund My Charity. In order to opt-out you can click on an unsubscribe link provided at the bottom of every commercial e-mail that you receive from Fund My Charity. If you opt-out, you will continue to receive communications from us relating to any payments you make or other services you request or purchase. Notwithstanding anything to the contrary herein, if you enter a sweepstakes on Fund My Charity via the alternative free method of entry, your information will only be used and disclosed as necessary for administration of the applicable sweepstakes, including, if applicable, fulfillment of the prizes.

B. Fulfillment of Services

We may retain other companies and individuals to perform certain functions on our behalf. Examples include, but are not limited to, companies and individuals who: (i) administer the Fund My Charity accounts; (ii) process donations; (iii) conduct surveys or promotional activities; (iv) deliver products; or (v) provide customer support, web hosting, internet service, and data analysis. Such third parties may be provided with access to your information needed to perform their functions but may not use such information for any other purpose.

C. Compliance with Law and Fraud Protection

We may disclose any information we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We may also exchange information with other companies and organizations for credit fraud protection, risk reduction and related activities or to protect the rights, property of safety of Fund My Charity, its agents, employees or affiliates or others. Fund My Charity reserves the right to use and to disclose to third parties the information of a user who we believe is in violation of our Privacy Policy or other terms as posted on the Site, even without a subpoena, warrant, court order or other governmental request, to the extent we deem necessary to protect the safety, security and rights of Fund My Charity and of third parties.

D. Sale or Transfer of Information

In the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets (a “Liquidation Event”) of Fund My Charity or the Site, or the diligence related to a Liquidation Event, your information may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of Fund My Charity or the Site in order to permit the party to continue the operation of Fund My Charity and/or the Site or any successor version of the Site. By using the Site, you consent to the sale and transfer of your information as described in this paragraph. Our successors and assigns may collect and use your information for substantially similar purposes as described in this Privacy Policy.

10. Credit Card Information

Fund My Charity does not collect, store or otherwise maintain any credit card information from individuals who make a donation through the Site. Donations, including information associated with your credit card, are processed by our partners, including Stripe, Network for Good and Amazon Payments.

A. Stripe

Stripe, based in San Fransisco, CA, is a credit card processor that allows you to access your money faster, and have it automatically transferred to your bank account on a daily, weekly or monthly basis. Donations will appear on the donor’s credit card statement under the name of the non-profit to whom they contributed. All donations made through Stripe go directly from the donor to the Non-Profit’s Stripe merchant account.

All information associated with your use of WePay will be handled in accordance with the terms of the https://stripe.com/us/legal. When you donate through Fund My Charity and use WePay to process your donation, you agree to the https://stripe.com/us/legal.

11. Information You Publicly Post

Any information you post publicly on the Site (“Publicly Available Content”) is available to the public without any expectation of privacy or confidentiality. Copies may remain viewable in cached and archived pages or if other users have copied or stored your Publicly Available Content even if you remove the Publicly Available Content. To request removal of your information from these areas of the Site, contact us using the information below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to do so and why. Minors may contact [email protected] to remove any such information immediately. The profile you create on our site will be publicly visible.

12. Information you Provide to Facebook and Other Social Networking Sites

The Site allows users to access Facebook to interact with friends and to share on Facebook through Wall and friends’ News Feeds. We do this currently through a third-party service. That third-party service may store some of the information as part of their provision of services to us. If you do not use Facebook or another social networking site (SNS) to log in then that third-party does not receive any data. If you are already logged into the Site and Facebook or another SNS, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to merge your profiles. If you are already logged into the Services but not logged into Facebook or another SNS that we support, when you click on “Connect with Facebook,” or a similar connection on another SNS, you will be prompted to enter your SNS credentials or to “Sign Up” for the SNS. By proceeding, you are allowing the Site to access your information and you are agreeing to the Facebook or other SNS’s Terms of Use in your use of the Services. Conversely, if you are not currently registered as a user of the Site, and you click on “Sign in” using Facebook or another SNS that we support, you will first be asked to enter your Facebook or SNS credentials and then be given the option to register for the Site. In this case, we may receive information from Facebook or another SNS to make it easier for you to create an Account on the Site and show our relevant content from your Facebook or SNS friends. Once you register on the Site and connect with Facebook or another SNS you will be able to automatically post recent activity back to Facebook or the other SNS. Any information that we collect from your Facebook or other SNS account may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices. Further, you can edit privacy settings for the reviews that appear on Facebook, or disconnect your Services activity stream by visiting the Facebook Applications Settings page.

14. Important Disclosures, Practices and Contact Information

A. Third-party Links

The Site may contain links to third-party websites. Please be aware that Fund My Charity cannot control and is not responsible for the information collection practices of such websites, which may differ from those of Fund My Charity. We encourage you to review and understand the privacy policies of these web sites before providing any information to them.

B. Data Security

We maintain a variety of safeguards designed to protect your information from unauthorized access, loss, misuse, alteration and disclosure. For example, we use industry accepted tools and techniques to protect against unauthorized access to our systems. We implement both physical and technological protocols to limit access to your information. These safeguards and tools vary based on the sensitivity of the information that we maintain about you.

You should be aware, however, that Fund My Charity has no control over the security of other websites on the Internet that you might visit even when a link may appear to those websites from our Site. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your information.

We want you to feel confident using the Site. However, no system can be completely secure. Therefore, although we take measures to secure your information, we do not promise, and you should not expect, that your information, searches or other communications always will remain secure. In the event of a breach of the confidentiality or security of your information, we will notify you if reasonably possible and as legally required so that you can take appropriate protective steps. We may notify you under such circumstances using the email address(es) we have on record for you. You should also take care with how you handle and disclose your information.

C. Children

The Site is not intended for persons under the age of 13. Fund My Charity does not knowingly market to, or solicit information, accept service or collect information from any person under the age of 13. If Fund My Charity becomes aware that any person submitting information to the Site is under the age of 13, we will attempt to delete the account and any related information as soon as possible. We require that only persons 13 years of age or older use the Site. By using the Site, you hereby represent that you are at least 13 years old.

D. Changes to this Privacy Policy

We may change this Privacy Policy, and any of our policies and procedures concerning our practices for managing your information, at any time and without prior notice subject to applicable law. When we post changes to this Privacy Policy, we will revise the updated date at the top of this Privacy Policy. If we make any material changes to our Privacy Policy, we only will notify you by sending an email to the email address(s) you provided to us, and by prominently posting notice of the changes on the Site. We recommend that you check the Site from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies. Any changes that are made to this Privacy Policy will apply to both any information that we hold prior to the effective date of the amended Privacy Policy and any information that we collect on or after such effective date.

E. Contacting Us

If you have any questions about Fund My Charity generally, this Privacy Policy or the Site, please feel free to contact us either by sending an email to [email protected] or through the Contact Us feature.

F. Users From Outside the United States

The Site is hosted in the United States and is governed by United States law. If you are visiting the Site from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Site, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

G. No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

H. California Privacy Rights

If you are a California resident, California law permits you to request certain information regarding our disclosure of “personal information” to third parties for their “direct marketing purposes” as such terms are defined by California’s Shine the Light Law (California Civil Code 1798.83). To make such a request, please email us or write us: [email protected]. We will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or postal address specified above. You should put “California Privacy Rights” in the subject line and in your request. You must provide Fund My Charity with specific information regarding yourself so Fund My Charity can accurately respond to the request.