Privacy Policy

VOW is committed to protecting your privacy.  This Privacy Policy, which is part of our Terms of Use, describes the information we collect through our website www.vowtoendchildmarriage.org (the “Site”), how we use and share it, and how you can make choices about our use of that information.  VOW is a Delaware nonprofit, nonstock corporation that is a fiscally-sponsored project of the Give Lively Foundation (“Give Lively”). As our fiscal sponsor, Give Lively accepts donations and administers funds on our behalf.

Please note that this Privacy Policy may be amended from time to time, so please check back regularly. By using the Site after we have posted an updated Privacy Policy, you agree to that updated Privacy Policy.

By using the Site, you consent to our collection, use, and sharing of information as described in this Privacy Policy.

Information We Collect

Information You Provide to Us

You can browse the Site without submitting any personally identifiable information (“Personal Information”) to us. We collect Personal Information, such as your name, email address, mailing address, and other information, when you voluntarily provide it to us. Below are the most common ways in which you would provide your Personal Information:

• When you submit information as part of a “Partner Inquiry”

• When you donate to VOW

• When you submit your email to learn more about VOW Information Automatically Collected

We may also collect information about users when you interact with the Site. This includes the IP address of the device you use to access the Site, the browser type, the time and date of visits to the Site, and the website that referred or linked you to the Site.  We may use this information to analyze how visitors use our Site so we can improve the quality of the information and services we provide.

We or our Service Providers (as defined below) may collect some of this information through cookies, web beacons, pixel tags, clear gifs or similar technologies. You are not required to accept cookies from the Site and may disable the cookies function, or delete existing cookies, by using your web browser’s options. If you disable or delete cookies, certain features of the Site may not work as intended.

The Site uses Google Analytics, a third-party website analytics tool that collects automated information about visitor traffic. The information collected by Google Analytics is transmitted to and stored by Google and will be subject to Google’s privacy policies. You can learn more about how to opt out of Google Analytics here.

We do not use information derived from this information automatically collected by the Site to identify visitors individually except in circumstances where we may deem it necessary in connection with legal process or to protect our rights or the rights of a third party as further described below.

How We Use Your Information

We will use your Personal Information for the following purposes:

• To send you information about news, events, or opportunities that we think may be of interest to you

• To respond to inquiries from you and communicate to you about your transactions with us • To process your donation

• To ensure and improve the quality of our Site

• To improve the content or services offered through our Site

• To detect, investigate, and protect against any activities that may violate our policies or the law and to establish, defend against, or enforce any related claims

How We Share Your Information

We may share your Personal Information with our third party service providers (“Service Providers”) that help us operate and provide services in connection with the Site. You can find a list of these Service Providers with links to their privacy policies at the bottom of this page. We recommend that you familiarize yourself with the Service Providers’ privacy policies if you have any privacy concerns.

We may use independent contractors, consultants, and third-party agents, affiliates, and partners to perform services on our behalf. These individuals and entities may have access to the Personal Information only as needed to perform their functions and are contractually obligated to maintain the confidentiality of any Personal Information collected from the Site.

We also reserve the right to disclose and use Personal Information and other information in special circumstances, including to enforce this Privacy Policy or any other part of our Terms, to comply with legal process or law enforcement, to address actual or suspected illegal activity, to protect our property or rights, to protect the rights and safety of anyone, or for other reasons we determine in good faith are necessary, appropriate, or required by law.  If we ever merge with, are acquired by, or otherwise consolidate with another organization, Personal Information may be transferred along with our other assets.

Donor Privacy

VOW values and respects the privacy of its donors. As with all other Personal Information, we do not share, loan, trade, rent, or sell our donor information to any other organization, nor will we send mailings to our donors on behalf of any other organization.

We maintain historical records of donor giving histories for certain types of gifts. This information is gathered so VOW’s fiscal sponsor can properly acknowledge gifts for IRS purposes and is also used by VOW to analyze giving histories.

Donor information may be made available to Service Providers, but only as necessary to accept, process, and/or acknowledge the donation or for VOW to provide its services.

This section applies to donations and donor information received online or offline.

Third-Party Web Sites The Site may contain links to third-party web sites and Service Providers (collectively, “Third-Party Sites”). Third-Party Sites may collect information about you when you interact with them through links on our Site. If you follow any link to a Third-Party Site, you should review those sites’ privacy policies to find out how they protect your privacy. We are not responsible for Third-Party Sites or their privacy practices.

Any online donations to support VOW are made through a Third-Party Site, and subject to the Third-Party Site’s privacy practices and terms of use.

Social Media Features

The Site may include social media features, such as Facebook, Instagram, or Twitter links and widgets.  When you interact with the Site through a social media platform, we may collect the Personal Information that you make available to us on that page, including your account ID or username and other information included in your posts. Social media features and widgets may be hosted and controlled by Third-Party Websites and your interactions with these features and widgets are governed by those respective companies’ privacy practices.

The Legal Basis for Processing Personal Information

In order to comply with applicable data protection laws, in particular the European Union General Data Protection Regulation (“GDPR”), we are required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for processing your personal data will typically be one of the following:

• where it is necessary to use your Personal Information in order to perform a contract that we have with you;

• where applicable law allows us to collect and use Personal Information for our own or third parties’ legitimate business interests (for example, in maintaining and promoting our business by providing customers with feedback opportunities or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest);

• when we have obtained your consent;

• to protect your vital interests; or

• where is necessary to use Personal Information in order to comply with our legal obligations.

Your Rights With Respect to Personal Information

Persons located in the European Economic Area may have certain rights in relation to their personal data under the GDPR. Persons in other jurisdictions may also have certain rights in relation to their personal data. We will honor your requests to exercise the following rights to the extent possible and required under the applicable law:

• Right to rectification. You may request that we rectify any inaccurate or incomplete personal data.

• Right to withdraw consent. You may at any time withdraw your consent to our processing of your personal data on the basis of your previous consent. Such withdrawal will not affect the lawfulness of processing based on such previous consent.

Right to make a subject access request (SAR). You may request in writing copies of your personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other individuals. Each request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and any payment permitted by law, where applicable.

Right to object to processing including automated processing and profiling. We do not make automated decisions about you. Profiling may be carried out for business administration purposes, such as monitoring trends in user visits of our Site. We will comply with valid objection requests unless we have a compelling overriding legitimate ground for the continuation of our processing or we have another lawful reason to refuse such requests. We will comply with each valid opt-out request in relation to marketing communications.

Right to erasure. You may request that we erase your personal data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the personal data, such as our business record retention obligations that we have to comply with.

Restriction. You may request that we restrict our processing of your personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as a legal obligation to continue processing your personal data in a certain way.

• Right to data portability. In certain circumstances, you may request we provide a copy of your personal data in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We do not consider that this right applies to us and our services. However, to the extent it does, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of your personal data which may still be retained for legitimate and lawful purposes.

Right to lodge a complaint with the supervisory authority. We recommend that you contact us about any questions or complaints in relation to how we process your personal data. However, you have the right to contact a relevant supervisory authority directly.

Record Retention

We will keep your Personal Information for as long as we need it, or as otherwise prescribed by law, for the purposes set out in this Privacy Policy.

Security

We use reasonable efforts to safeguard your Personal Information. All transmissions to the Site related to donations, including transmission of Personal Information associated with such donations, are secured and encrypted. Of course no transmission over the Internet can be guaranteed to be 100% secure, so you provide your Personal Information at your own risk.

Location of Servers and Transfer of Information

Information collected through the Site will be accessed and processed in the United States. In addition, your information may be transferred outside the United States by our Service Providers with locations in other countries. By using the Site and providing your Personal Information to us, you consent to this transfer and to the collection, storage, processing and use of your Personal Information both within and outside of the United States.

Your Choices Regarding Our Use of Your Personal Information If you wish to review, update, correct, or remove the information we have for you, please contact info@vowtoendchildmarriage.org. If you no longer wish to receive communications from us, you can also unsubscribe by clicking on the “unsubscribe” button in any email communication you receive from us. Some browsers have incorporated Do Not Track (“DNT”) preferences. As there is not yet an industry-standard DNT protocol on how to interpret DNT signals, we do not honor DNT signals from browsers at this time. However, you may refuse or delete cookies to prevent tracking activities.

Children

The Site is directed at an adult audience and we do not knowingly collect information from or about children.

Changes to this Privacy Policy VOW reserves the rights to modify this Privacy Policy from time to time without notice to you. If we make substantial material changes to our Privacy Policy, we will notify you. VOW may update this Privacy Policy by posting a new version on this webpage.

Your California Privacy Rights

If you reside in California and have provided your Personal Information to us, you may request information once per calendar year about our disclosures of certain categories of your Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing at the following email address: info@vowtoendchildmarriage.org.

Contact Us

For any questions you may have about this Privacy Policy or our data practices please contact info@vowtoendchildmarriage.org. As of 10/8/2018, VOW uses the following Service Providers to operate the Site: • Media Temple (web hosting) (Privacy Policy)

• Give Lively (donation acceptance and administration) (Privacy Policy)

• Mail Chimp (email management) (Privacy Policy)

• Google Analytics (website analytics) (data practices)

Last updated: 10/8/2018