PRIVACY POLICY FOR B1G1 GIVING, INC.

‍1. The Information We Collect

1.1: Personal Data Defined. In this Privacy Policy, Personal Data refers to any data, whether true or not, about an individual who can be identified: (a) from that data, or (b) from that data and other information to which we have or are likely to have access, including data in our records as they may be updated from time to time. Examples of such Personal Data you may provide to us include your name, passport or other identification number, telephone number(s), mailing address, email address, photographs or videos, credit card or bank account numbers, network or transactional data, and any other information relating to any individuals which you have provided to us electronically or in any forms you may have submitted to us, or via any other kinds of interaction between us.

1.2: When and How We Collect Personal Data. Generally, we collect Personal Data in the following ways:

a. When you register a user account at a B1G1 Giving Site or App;

b. When you conduct any online transactions (such as making a contribution to a B1G1 Giving Worthy Cause) on a B1G1 Giving Site or App;

c. When you download or use any of our Apps;

d. When you apply for approval as a Worthy Cause, or contact us to gather information about participation in our program;

e. When you use a cookie-enabled browser to visit a B1G1 Giving Site or use a B1G1 Giving App (cookies are discussed further in Section 2 below);

f. When you subscribe to our mailing lists for email subscription, postal mail contacts, or other forms of regular or occasional communication with us;
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g. When you interact with members of our B1G1 Giving Team via telephone calls, emails, letters or face-to-face meetings, when you submit a comment or question to us using a Contact Us or similar feature on our websites, or when you contact us in any other way and disclose your Personal Data;

h. When your images are captured by us during video calls we may conduct, or via photographs or videos taken by us or our representatives when you attend events hosted by us;

i. When you provide or offer to provide volunteer services to us, whether as part of a team project (e.g., a student team) or on an individual basis;

j. When we solicit information about you and receive your Personal Data from third parties such as employment agencies, former employers, references, or government authorities; and

k. When you submit your Personal Data to us for any other reason.
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1.3: Voluntary Nature of Data Collection. When you browse our Site or use our Apps, you generally do so anonymously, except as described in the section below on cookies. On our Site or Apps, we do not automatically collect Personal Data, such as your email address, unless you affirmatively provide that information or log in with your account credentials.

‍1.4: Third-Party Information. If you provide us with any Personal Data relating to a third party (including but not limited to information about your customers, beneficiaries, spouse, children, parents and/or volunteers or employees), by submitting such information to us, you represent that you have obtained the consent of that third party (or in the case of children, the consent of a parent or legal guardian) to you providing us with their Personal Data for the respective purposes. If you have not obtained the consent of the third party, please do not submit their Personal Data to us.

1.5: Children’s Data. We do not direct our Site, Apps or Services to users under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us at B1G1 Giving, Inc., 16192 Coastal Highway, Lewes, Delaware 19958, USA or by sending an email to privacy@b1g1.org.

‍1.6: Accuracy of Personal Data Submitted. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. A failure on your part to do so may result in our inability to provide you with the products and services you have requested. See Section 9 below regarding correction of your Personal Data in our files.  

2.0 Information We Automatically Collect; Cookies

2.1: Cookie Defined. A cookie is a small piece of information that is placed on your computer or other electronic device when you visit certain websites; it allows the website to remember you, or certain data about you. The cookies placed by our server can only be read by our system, and cookies cannot access, read or modify any other data on an electronic device.

2.2: How We Use Cookies. B1G1 Giving uses cookies on its Site and Apps for the following purposes:

• To enable certain features and functions on our Site and Apps, such as remembering your User ID, your favorite Worthy Cause selections, and browsing and other service preferences;

• To build up a profile of how you and other users use the Site and Apps (including but not limited to monitoring how a visitor arrives at the website, what kind of browser the visitor is on, what operating system a visitor is using, a visitor’s IP address and such clickstream data as which pages a visitor viewed, the time the pages were accessed and the time spent on each web page);

• To improve the efficiency of our Site and Apps;

• To administer services to you and to our Worthy Cause partners;

• To track usage statistics; and

• For other purposes which are reasonably related to the above.

2.3: Disabling Cookies on Your Device. Most web browsers offer you the option to disable the processing of cookies, and if you decide to do so, then we do not gather any information concerning you unless you otherwise agree to provide it. However, if you do disable cookies on your device, you may not be able to enter or fully use certain parts of our Site or Apps.

‍2.4: Links to Third-Party Websites. Our Site and Apps contain numerous links to third party websites operated by our Worthy Cause partners, service providers and other third parties. Bear in mind that these third party links may generate their own cookies to track how many people have seen a link or advertisement, how frequently they have seen it, and for other purposes. B1G1 Giving is not responsible for the content, security or Personal Data policies (including but not limited to the cookie usage practices) of any third party websites linked to any B1G1 Giving Site or Apps.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data
 
3.1: Customary Uses. As a general practice, B1G1 collects, uses and discloses your Personal Data for the following purposes:

a. To respond to your queries, feedback, complaints and requests;

b. To verify your identity;

c. To manage the administrative and business operations of B1G1 Giving, and complying with its internal policies and procedures;

d. To match any Personal Data held which relates to you for any of the purposes listed herein;

e. To prepare and publish reports (including but not limited to Annual Reports, media announcements, blogs, social media postings and similar public announcements);

f. To prevent, detect and investigate fraud or other criminal activity, including but not limited to possible violations of US OFAC and Terrorist List restrictions, and to analyse and manage commercial risks;

g. To manage the safety and security of our premises and services (including but not limited to conducting security clearances);

h. To monitor or record phone calls or video calls and customer-facing interactions for quality assurance and for identity verification purposes;

i. In connection with any claims, actions or proceedings and/or to protect and enforce our contractual and legal rights and obligations;

j. To conduct investigations relating to disputes, billing or fraud;

k. To meet or comply with applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on B1G1 Giving (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, and conducting audit checks, due diligence and investigations); and

l. For other purposes which are reasonably related to the above.

Processing of your Personal Data takes place on the following legal bases, as the case may be:
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• You have given consent to the processing of your Personal Data for one or more specific purposes;
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• Processing is necessary for the performance of an agreement with B1G1 Giving or in order to take steps at your request prior to entering into an agreement;

• Processing is necessary for compliance with a legal obligation to which B1G1 Giving is subject;

• Processing is necessary in order to protect your vital interests or those of another natural person;

• Processing is necessary for the performance of a task carried out in the public interest; and

• Processing is necessary for the purposes of the legitimate interests pursued by B1G1 Giving or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data (in particular when you are a child).

3.2: Administering Our Worthy Cause Program. In addition, B1G1 Giving collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

a. If you are making a contribution to one of our approved Worthy Causes, facilitating your contributions (including but not limited to tracking amounts contributed, making remittances, tracking the impacts from your contributions, corresponding with you regarding your contributions, and corresponding with Worthy Causes on your behalf);

b. If you are a B1G1 Giving approved Worthy Cause or are interacting with us regarding possible participation in our program as an approved Worthy Cause, investigating the background of your organization, reviewing its legal and financial records, assessing on an ongoing basis the organization’s compliance with the terms and conditions governing its participation in our program, and facilitating the raising and remittance of funds to your projects (including but not limited to managing project information and outcomes, tracking the receipt and use of funds, and corresponding with donors on your behalf); and

c. If you serve or offer to serve as a member of the B1G1 Giving Board, conducting a screening of your professional and personal background, facilitating onboarding processes (including but not limited to creating system access profiles), and ensuring compliance (both by you and by B1G1 Giving) with all legal and regulatory requirements, as well as with internal B1G1 Giving policies.

4. Disclosure of Your Personal Data
 
B1G1 Giving will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties:

a. Our affiliated corporate entity, specifically BUY1GIVE1 Pte. Ltd., headquartered in Singapore;

b. Companies providing B1G1 Giving with services relating to the operation of its businesses (including but not limited to consulting, courier services, telecommunications, information technology, banking, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security, employee recognition and other services);

c. Banks, credit card companies and their respective service providers;

d. Our professional advisors such as consultants, auditors and lawyers;

e. Relevant government ministries, regulators, statutory boards or other authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any such governmental authority;

f. A third-party organization, if B1G1 Giving merges with, or becomes an affiliate of such organization; provided, however, that in such an event we will ensure the confidentiality of any Personal Data involved in such transactions and provide notice before Personal Data is transferred and becomes subject to a different privacy policy; and

g. Any other party to whom you authorise us to disclose your Personal Data.


5. Data Security
 
5.1: Our Security Arrangements. B1G1 Giving will take reasonable physical, technological and organizational precautions to avoid (i) unauthorized access to your Personal Data, and (ii) loss, abuse or alteration of your Personal Data. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that, for example, no harmful code will enter our website (including but not limited to viruses, bugs, Trojan horses, spyware or adware). You should be aware of the risks associated with using websites and Apps.

‍5.2: Your Obligations. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser. You undertake to keep your username and password secure and confidential, to refrain from disclosing it or permitting it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. As set forth in our Terms of Service, we are not liable for any damages resulting from any security breaches resulting in whole or in part from unauthorised or fraudulent use of your username and password.

6. Third-Party Websites
 
Our Site and Apps may contain links to other websites or applications operated by third parties. We are not responsible for any of the privacy practices of websites or applications operated by third parties that are linked to our Site/Apps. We encourage you to learn about the privacy policies of such third parties. Some of these third party websites/applications may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our Site/App, you should check the applicable Personal Data policies of the third party website/application to determine how they will handle any information they collect from you.  

7. Storage of Data, Retention
 
Our data is stored on servers of our hosting service provider (Digital Ocean, which is certified under the Privacy Shield program) in Singapore.Unless a longer storage period is required or justified (i) by the law or (ii) through compliance with another legal obligation, B1G1 Giving shall only store your Personal Data for the period necessary to achieve and fulfil the purpose in question, as specified in this Privacy Policy.  

8. Your Privacy Rights
 
Any data subject has the right to exercise their privacy rights. Those rights entail:

• Right of access to Personal Data which B1G1 Giving possibly has concerning you;

• Right to rectification, completion or update of your Personal Data;

• Right to delete your Personal Data;Right to limit the processing of your Personal Data;

• Right to transferability of your Personal Data;

• Right to object to/oppose the processing of your Personal Data; and

• Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.If you wish to invoke your privacy rights as defined above, please send us an email at privacy@b1g1.org.
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If you no longer wish to receive newsletters or information about our services, you can unsubscribe at any time by clicking the “unsubscribe” button at the bottom of each of B1G1 Giving’s emails.  

9. Contacting Us
 
9.1: Contacting Us. If you: (a) have any questions or feedback relating to your Personal Data or our Privacy Policy; (b) would like to withdraw your consent to any use of your Personal Data as set forth in this Privacy Policy; or (c) would like to obtain access to and, if appropriate, correct your Personal Data records, you can do so by contacting us at: B1G1 Giving, Inc., 16192 Coastal Highway, Lewes, Delaware 19958, USA or sending an email to privacy@b1g1.org.

‍9.2: Contacting Third-Party Companies. We employ a variety of third party companies to help us manage our business, including our Site and Apps. Where these third parties have granted us access to their systems, if you contact us for access to and (if necessary) corrections to your Personal Data, we will take prompt action to address your request. Please note that in certain cases, you have supplied your Personal Data directly to these third parties, and the third parties have not granted us permission to access their data. In these cases, you must contact the third party directly to access and correct (if necessary) their data; if you contact us, we will make any appropriate corrections to our systems, but those changes will not affect the underlying data in the third party’s system. You must contact them directly to change your Personal Data in their systems. We will facilitate your request to the extent that we are able to do so, but we are not responsible for their practices.