Date of Last Review: May 2018

Transcription

1 Date f Last Review: May 2018

2 PURPOSE AND SCOPE This privacy plicy cvers all websites frm the dmain, either thrugh a-recrd, sub-dmain, frwarding, re-directing (cllectively "YurCause.cm") and any ther dmains wned by YurCause, LLC ("YurCause") including and (the Site(s) ), as well as all technlgy platfrms and services (a) prvided thrugh the Sites; r (b) that specifically link t r reference this Privacy Plicy (cllectively with the Sites, the Services ). YurCause, LLC ("YurCause", us, we, r ur ) has created this Privacy Plicy ( Privacy Plicy ) t demnstrate ur cmmitment t privacy fr Custmers, Partners, Authrized Users, and visitrs f its Services and t infrm yu f ur plicies and prcedures regarding the cllectin, use and disclsure f persnal infrmatin we receive fr YurCause s Sites and Services. Privacy n the Sites and within Services delivered by YurCause t ur users is f utmst imprtance t us. Authrized Users are users wh register t use the Sites r Services either thrugh a persnal accunt, r thrugh r n behalf f a Custmer, Charitable Organizatin r Partner. (Authrized Users may be referred t in this Privacy Plicy as members, dnrs, users r yu.) Partners are parties wh have arrangements with YurCause t prvide certain Services t ther Custmers, Authrized Users, r Charitable Organizatins. Visitrs are individuals wh view the Sites. Any agreements between YurCause, LLC and the cmpany cntracting ur Services ( Cmpany ), and their respective terms and cnditins regarding data, privacy and accessibility, may take precedent ver this Privacy Plicy, as stated within such executed agreements. This Privacy Plicy applies nly t infrmatin that is prvided t us thrugh the Services (including that which we may cllect n yur behalf) when using ur Site Services. Yur use f any f the Services cnstitutes yur acceptance f this Privacy Plicy, the Terms f Use, and the cllectin and use f yur infrmatin in accrdance with this plicy. If yu d nt accept any aspect f this Privacy Plicy r the Terms f Use, yu shuld nt use the Sites. As used in this plicy, the terms using and prcessing infrmatin include using ckies n a cmputer, subjecting the infrmatin t statistical r ther analysis and using r handling infrmatin in any way, including, but nt limited t cllecting, string, evaluating, mdifying, deleting, using, cmbining, disclsing and transferring infrmatin within ur rganizatin r amng ur affiliates within the United States r internatinally. YOUR USE OF THE SITE ACKNOWLEDGES THAT YOU HAVE READ, ACCEPTED, AND AGREED TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO ALL THE TERMS OF THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO ACCESS THE SITE OR SERVICES AND NEITHER YOU SHALL NOT BE ABLE TO USE OR RECEIVE THE BENEFIT OF THE SITE OR SERVICES. Questins regarding this Plicy shuld be ed t supprt@yurcause.cm. If yu encunter a screen r page that requests infrmatin yu d nt want t share with us, d nt enter the infrmatin and d nt prceed with that screen r page. INFORMATION COLLECTION AND USE, INCLUDING DATA TRANSFERS RECEIVED FROM CLIENTS AND THIRD PARTIES We cllect tw types f infrmatin frm yu when yu visit ur Sites r use ur Services: (1) "persnally identifiable infrmatin" ("PII") (as defined belw) and (2) nn-persnally identifiable infrmatin ("NPII") (as defined belw). PII fr the purpses f this Privacy Plicy is infrmatin that identifies yu persnally, such as yur name, address, telephne number, address. Fr users lcated in the EU, references t PII in this Privacy Plicy are equivalent t what is cmmnly referred t as Persnal Data in the EU.

3 i. Persnally Identifiable Infrmatin In the curse f using the Services (including a Hsted Applicatin), we may ask yu t prvide us with certain persnally identifiable infrmatin ( PII ) that can be used t cntact r identify yu and administer yur accunt. Persnal Infrmatin includes, but is nt limited t, yur name, phne number, credit card r ther billing infrmatin, address and hme and business pstal addresses. We transmit credit card infrmatin directly t ur prcessing partners thrugh a secure (as they exist at the time this plicy is implemented) API integrated within the Site ver a reasnably secure cnnectin. We d nt stre any credit card details (credit card number, expiratin date, Card Verificatin Value). We d stre the user's cntact infrmatin (mre details prvided belw). We use yur Persnal Infrmatin (in sme cases, in cnjunctin with yur Nn-Identifying Infrmatin) t prvide the Services, cmplete yur transactins, administer yur inquiries, and as further explained belw. ii. We use PII t prvide the Services, fr trubleshting and maintenance f the Site and Services, and t cmmunicate with Custmers, Charitable Organizatins, and Authrized Users. We als use PII t: help us create and publish cntent mst relevant t yu; cntrl access t certain areas f ur Sites and Services; register Authrized Users and develp their prfiles and enable them t take advantage f the persnalized features f ur Site and Services; prcess transactins requested by ur Custmers, Charitable Organizatins, and Authrized Users; and cmmunicate in respnse t request frms such as "Cntact Us". Nn-Persnally Identifiable Infrmatin Certain Nn-Persnally Identifying Infrmatin ( NPII ) wuld be cnsidered a part f yur Persnal Infrmatin if it were cmbined with ther identifiers (fr example, cmbining yur zip cde with yur street address) in a way that enables yu t be identified. But the same pieces f infrmatin are cnsidered Nn-Identifying Infrmatin when they are taken alne r cmbined nly with ther nn-identifying infrmatin (fr example, yur viewing preferences, yur age, gender, r interests). We may cmbine yur Persnal Infrmatin with Nn-Identifying Infrmatin and aggregate these tw sets f infrmatin with infrmatin cllected frm ther YurCause digital prperties t prvide yu with a better experience, t imprve the quality and value f the Services and t analyze and understand hw ur Site and Services are used. We may als use the cmbined infrmatin t serve yu specifically, fr instance t deliver a prduct t yu accrding t yur preferences r restrictins. Here are sme examples f the ways in which we may cllect and stre yur nn-persnally identifiable infrmatin thrugh ur services, and hw we use such infrmatin: Lg Infrmatin. When yu use ur services r view cntent prvided by YurCause, we autmatically cllect and stre certain infrmatin in ur server lgs. This type f infrmatin includes details f hw yu used ur service, IP address infrmatin described belw, web pages which have been viewed by a visitr, data and time, dmain type, device event infrmatin such as crashes, system activity, hardware, settings, brwser type r versin, brwser language, the date and time f yur request and referral URL. Internet Prtcl (IP) address. Yur "IP address" is a number that lets cmputers attached t the Internet knw where t send yu data, such as the screens and pages f ur services that yu view. We use this infrmatin t deliver ur screens and pages t yu upn request, t tailr ur services t the interests f yu and ur ther visitrs, and t measure traffic t and within ur services.

4 Demgraphic Infrmatin. "Demgraphic infrmatin" may be yur gender, age, zip cde, and interests. We may cllect such infrmatin abut yu thrugh ur services and use it t prvide yu with persnalized services and t analyze trends t ensure that ur services and the infrmatin n them is targeted t meet yur needs. Please nte that we als cnsider aggregated infrmatin, which is nt persnally identifiable, t be nn-persnally identifiable infrmatin. Device Infrmatin. "Device Infrmatin" may include infrmatin we cllect such as yur hardware mdel, perating system versin, unique device identifiers and mbile netwrk infrmatin including phne number. We may assciate yur device identifiers r phne number with yur accunt. Lcatin Infrmatin. When yu use YurCause Services we may cllect and prcess infrmatin abut yur actual lcatin. We use varius technlgies t determine lcatin, including IP Address, Glbal Psitining Systems and ther sensrs that may prvide YurCause with infrmatin abut nearby devices, Wi-Fi access pints and cell twers. YurCause des nt sell, lend, rent, r lease yur Persnally Identifiable Infrmatin. Except as described in this Privacy Plicy, yur Persnally Identifiable Infrmatin will be used nly by YurCause and its cntrlled subsidiaries, affiliates, agents, r cntractrs, and verified partners and yur Persnal Infrmatin will nt be disclsed t any nn-qualified partner and/r third party withut yur prir cnsent. YurCause will stre all cllected PII until yu request we purge r edit yur data frm ur systems. At that pint, the requested PII will be scheduled fr deletin r mdificatin. We d nt share yur credit card infrmatin with any entity ther than the payment card prcessr. We d nt retain yur credit card infrmatin. We may share infrmatin abut yur dnatin with Cmpany in rder t prvide the services. We may share infrmatin prvided in yur prfile page ( My Prfile ) with Cmpany if misuse f ur services ccurs, in rder t cntinue t prvide the services. Persnal infrmatin may be disclsed t judicial r ther gvernment agencies subject t warrants, subpenas, r ther gvernmental rders. iii. Dnatin Prcessing YurCause prcesses dnatins thrugh ur partner APIs. Visit the websites fr ur partner APIs, including Heartland Payment Systems, Netwrk Fr Gd, CanadaHelps, Charities Trust, and United Way Wrldwide fr additinal infrmatin related t tax deductins, tax receipt, prcessing fees and the privacy plicies fr thse websites. iv. Ckies Like many websites, we use ckies t cllect certain infrmatin frm visitrs t the Sites and users f the Services, such as Internet addresses, brwser types, referring dmains, time stamps (time page accessed as well as time spent per web page), as well as the specific pages the visitr has requested. This infrmatin is lgged fr marketing purpses and t help diagnse technical prblems and administer the Sites and the Services in rder t cnstantly imprve the quality f the Services. We may als track and analyze nn-identifying activity and aggregate usage-and-vlume statistical infrmatin frm visitrs and users and prvide such infrmatin t third parties. We d nt link this autmatically cllected data t ther infrmatin we cllect abut yu. A ckie is a small data file that we transfer t yur cmputer s hard disk fr recrd-keeping purpses. We and ur partners, affiliates, r website analytics r service prviders use technlgies such as ckies, beacns, tags, and scripts, t analyze trends, administer the website, tracking users mvements arund the website, and t gather demgraphic infrmatin abut ur user base as a whle. We may receive reprts based n the use f these technlgies by these cmpanies n an individual and aggregated basis.

5 We use tw types f ckies. Sessin ckies, which link yur actins during a particular brwser sessin and expire at the end f that sessin, as well as persistent ckies, which remain n yur device and allw us t remember yur actins r preferences acrss multiple brwser sessin. At YurCause, we make use f ckies fr the fllwing business purpses: Security We use authenticatin ckies t ensure yu nly access data intended fr yur view and prevent unauthrized access f yur credentials and infrmatin. Operatinal URL redirectin is a prcess by which ur Site cmmands yur brwser t redirect yu t a page based n the value stred in the redirectin ckie we cnfigured. We als use Lcal Strage, als knwn as HTML5 Web Strage, t stre cntent infrmatin and preferences in rder t prvide users a better experience n ur sites. We d nt use HTML5 Web Strage t display advertising based upn yur web brwsing activity. Varius brwsers may ffer their wn management tls fr remving Lcal Strage/HTML5 Web Strage. Analytical T better understand hw ur users interact with ur Site and aggregate infrmatin n users engagement with ur Services, we use an analytics tl that may stre ckies n yur device n ur behalf YurCause uses Ggle Analytics, a third-party service prvider, t cllect and prcess data thrugh the use f ckies. Fr additinal infrmatin abut hw Ggle uses data when yu use YurCause, please see If yu are cncerned abut having ckies n yur cmputer, yu can set yur brwser t refuse all ckies r t indicate when a ckie is being set, allwing yu t decide whether t accept it. Yu can als delete ckies frm yur cmputer. The Help feature n mst web brwsers will tell yu hw t prevent yur brwser frm accepting new ckies, hw t receive ntice when a new ckie is set, and hw t disable ckies altgether. Hwever, if yu chse t blck r delete ckies, certain features f ur websites may nt perate crrectly and the fllwing may ccur: If yu change the settings n yur web brwser, yu will be presented with the cnsent ptin again the next time yu visit ur website. Unless yu have adjusted yur brwser setting s that it will refuse ckies, ur system will issue ckies when yu visit this website. Fr further infrmatin abut deleting r blcking ckies, please visit: SHARING OF INFORMATION BY YOURCAUSE Other than as expressly described in this Privacy Plicy, YurCause will nt share, sell r rent a user s r a visitr s persnally identifiable infrmatin r hsted data with anyne utside f YurCause, withut such user s r visitr s prir permissin r unless rdered by a curt f law and when we believe that disclsure is necessary t prtect ur rights, prtect yur safety r the safety f thers, investigate fraud and/r t cmply with a judicial prceeding, bankruptcy prceedings, curt rder, r legal prcess served n the Site. Persnally identifiable infrmatin. Primarily, we may share r disclse yur persnally identifiable infrmatin in the fllwing instances: T identify yu t a Charitable Organizatin t which yu have made a dnatin, unless yu chse t be annymus.

6 The YurCause Services and technlgy platfrm transfers PII data t certain third-party dnr-advised fund(s) ( DAF s ) such as DnateWell, r ther similar DAF s fr purpses f managing individual dnr DAF accunts and funds disbursements, fr thse Clients wh utilize the DAF. YurCause may transfer persnal infrmatin t cmpanies that help us prvide ur service. All such transfers t subsequent third parties are cvered by cnfidentiality agreements with the third parties. T unaffiliated third-party service prviders, agents, r independent cntractrs wh help us maintain ur services and with ther administrative services (including, but nt limited t, rder prcessing and fulfillment, prviding custmer service, maintaining and analyzing data, sending custmer cmmunicatins n ur behalf, and entry cllectin, winner selectin and prize fulfillment fr cntests, sweepstakes, and ther prmtins). We seek t ensure that such unaffiliated third-parties will nt use yur persnally identifiable infrmatin fr any purpse ther than that fr which they are respnsible. Hwever, we cannt guarantee that they will nt use it fr any ther purpse. If yu chse t make a dnatin r receive disbursements n r thrugh ur Services, we may ask yu fr yur credit card number, billing address, and ther infrmatin in cnnectin with cmpleting such purchase, and we may use such infrmatin t fulfill yur purchase. We may als prvide such infrmatin, r ther persnally identifiable infrmatin prvided by yu, t third-parties (such as Stripe, Inc. r a similar prcessr) (a Payment Prcessr ) t cmplete yur transactin (fr example, t prcess yur credit card). The Payment Prcessr is acting slely as a billing and prcessing prvider fr and n behalf f YurCause and shall nt be cnstrued t be prviding the applicable Service. In additin, the Payment Prcessr is an entity cmpletely independent f YurCause, YurCause exercises n cntrl ver the peratins f the Payment Prcessr, makes n warranties r representatins n behalf f such Payment Prcessr, and accepts n liability in respect f the acts r missins f the Payment Prcessr (including expressly with respect t any Security Breach). The Payment Prcessr s use f yur PII and NPII is subject t the terms, cnditins, and privacy plicies published by such Payment Prcessr (which, with respect t Stripe, are available at T cmply with law, r in the gd faith belief that such actin is necessary t cnfrm t the requirements f law, r cmply with legal prcess served n us, and t prtect and defend ur rights r prperty, including ur rights and prperty and ur services, r act in urgent circumstances t prtect the persnal safety f yu and ur ther visitrs. T track and analyze nn-identifying, aggregate usage and vlume statistical infrmatin frm ur visitrs and custmers and prvide such infrmatin t third parties. T prtect against fraud and ptential fraud. We may verify the infrmatin yu prvide using ur Services thrugh third parties. In the curse f such verificatin, we may receive additinal persnally identifiable infrmatin abut yu frm such Services. In particular, if yu use a credit card r debit card t purchase services with us, we may use card authrizatin and fraud screening services t verify that yur card infrmatin and address match the infrmatin yu supplied t us, and that the card has nt been reprted as lst r stlen. We may share infrmatin abut yur dnatin with Cmpany in rder t prvide the services. We may als share infrmatin prvided in yur prfile page ( My Prfile ) with Cmpany if misuse f ur services ccurs, in rder t cntinue t prvide the services. Nn-persnally identifiable infrmatin. We may share and disclse yur nn-persnally identifiable infrmatin fr the purpses described in this statement r where it is cllected, r any ther legal purpse, including, when and where applicable, sharing and disclsing nn-persnally identifiable infrmatin cmbined with persnally identifiable infrmatin. Legal Disclsure. We may disclse infrmatin abut yu and yur use f the services if we believe that such disclsure is reasnably necessary t:

7 (i) (ii) (iii) (iv) Cmply with the law and/r legal prcess where a frmal request has been made (e.g. request frm an administrative versight agency, civil suit, subpena, curt rder r judicial r administrative prceeding); Prtect r defend ur rights and/r prperty r the rights and prperty f thers; Enfrce ur Terms and Cnditins, ther agreements, and/r this Privacy Plicy; Respnd t claims that the cntent(s) f a cmmunicatin vilates the rights f anther. SHARING OF INFORMATION BY CUSTOMERS AND CHARITABLE ORGANIZATIONS YurCause Custmers r Charitable Organizatins may chse t share PII data related t its emplyees in rder t supprt charitable giving prgram management. It is the respnsibility f each Custmer r Charitable Organizatin t ntify its emplyees that PII data is shared with YurCause. YurCause will cperate with its Custmers and Charitable Organizatins, hwever, t help them prvide ntice t their users cncerning the purpse fr which persnal infrmatin is cllected. Neither YurCause nr the Sites slicit the users n behalf f unrelated, thirdparty marketers. CHANGING OR DELETING YOUR INFORMATION We will retain persnal data we cllect, as well as persnal data we cllect and prcess n behalf f ur Partners, fr as lng as needed t prvide ur Services. YurCause will retain and use this persnal infrmatin as necessary t cmply with ur legal bligatins, reslve disputes, and enfrce ur agreements. All registered users may review, update, crrect r delete the Persnal Infrmatin in their registratin prfile by cntacting YurCause and/r the apprpriate individuals at their emplyer. If a user s prfile infrmatin is deleted, then the user s accunt will becme deactivated. If yu wuld like us t delete yur recrd in ur system, please cntact us with a request that we delete yur Persnally Identifiable Infrmatin frm ur database. We will use cmmercially reasnable effrts t hnr yur request and will wrk with the emplyer cntracting with YurCause t ensure yur data is prperly remved within a reasnable time (thugh sme infrmatin may nt be erasable, as described abve). We will retain yur infrmatin fr as lng as yur accunt is active r as needed t prvide yu services. If yu wish t cancel yur accunt r request that we n lnger use yur infrmatin t prvide yu services, yu may d s in yur user accunt settings, r yu may cntact us at supprt@yurcause.cm. We will respnd t yur request within a reasnable timeframe. We will retain and use yur infrmatin as necessary t cmply with ur legal bligatins, reslve disputes, and enfrce ur agreements. SECURITY At YurCause, we are very cncerned with safeguarding all infrmatin, as the prtectin f the data yu share with us is very imprtant. YurCause uses generally accepted industry practices t help prevent unauthrized use f, access t r alteratin f visitr and user infrmatin and hsted data. These practices include the use f firewalls, SSL encryptin, system redundancies, and c-lcatin at a 24/7 mnitred, access-cntrlled envirnment. YurCause persnnel with access t infrmatin gathered frm visitrs and users have been advised f the imprtance f maintaining the cnfidentiality f such infrmatin and f using it nly fr the purpses described in this Privacy Plicy.

8 All sensitive data yu transmit t us via ur Site is encrypted using industry standards as they exist at the time this plicy is implemented bth in transit ver HTTPS using the Transprt Layer Security prtcl ( TLS ) and at rest using Transparent Data Encryptin and ther encryptin standards f data at rest. All sensitive data we cllect frm yu (such as credit card infrmatin fr the purpse f making a dnatin) is encrypted and transmitted t ur prcessing partner when applicable, in a reasnably secure manner (where the data is encrypted ver TLS using the Advanced Encryptin Standard with a key length f 256 bits). Yu can verify the cnnectin security by lking fr a lck icn n yur brwser address bar. We will make any legally required disclsures f any breach f the security, cnfidentiality, r integrity f yur electrnically stred PII in accrdance with apprpriate legal r regulatry requirements, taking int accunt the need t accmmdate (i) legitimate requests by law enfrcement and (ii) any measures reasnably necessary t investigate the scpe f the breach and restre the reasnable integrity f the data system. If yu have any questins abut security n ur Web site, yu can learn mre at r cntact us at supprt@gddnegreat.cm. SWISS U.S. PRIVACY SHIELD FRAMEWORK YurCause cmplies with the Swiss U.S. Privacy Shield Framewrk as set frth by the US Department f Cmmerce regarding the cllectin, use, and retentin f persnal infrmatin frm Switzerland t the United States. YurCause has certified that it adheres t the Privacy Shield Principles f ntice, chice, nward transfer, security, data integrity, access, and enfrcement. If there is any cnflict between the plicies in this privacy plicy and the Privacy Shield Principles, the Privacy Shield Principles shall gvern. T learn mre abut the Swiss U.S. Privacy Shield and t view ur certificatin page, please visit Yu may direct any cmplaints pertaining t ur cllectin and/r use f yur infrmatin t us at: security@yurcause.cm r by mail at YurCause Security Office 6111 West Park Blvd. Suite 1000 Plan Texas, In cmpliance with the Swiss U.S. Privacy Shield Principles, YurCause cmmits t reslve cmplaints abut yur privacy and ur cllectin r use f yur persnal infrmatin. If yu are unsatisfied with the reslutin f yur cmplaint, please cntact the independent recurse mechanism listed belw: HR Data Recurse Mechanism YurCause cmmits t cperate with the Swiss authrity r authrities, including the Swiss Federal Data Prtectin and Infrmatin Cmmissiner, cncerned in cnfrmity with the Supplemental Principles n Human Resurces Data and the Rle f the Data Prtectin Authrities. YurCause will cmply with the advice given by such authrities. Nn-HR Data Recurse Mechanism YurCause has cmmitted t refer unreslved privacy cmplaints under the Swiss U.S. Privacy Shield Principles t PrivacyTrust, an alternative dispute reslutin prvider. If yu d nt receive timely acknwledgment f yur cmplaint frm us, r if we have nt addressed yur cmplaint t yur satisfactin, please cntact r visit PrivacyTrust s dispute reslutin prtal at fr mre infrmatin r t file a cmplaint. The services f the PrivacyTrust are prvided at n cst t yu. EU U.S. PRIVACY SHIELD FRAMEWORK

9 YurCause recgnizes that the EU has established certain prtectins regarding the handling f EU Persnal Data, including requirements t prvide adequate prtectin fr EU Persnal Data transferred utside f the EU. T prvide adequate prtectin fr certain EU Persnal Data abut crprate custmers, clients, suppliers, and business partners received in the US, YurCause has elected t self-certify t the EU-US Privacy Shield Framewrk administered by the US Department f Cmmerce ( Privacy Shield ). YurCause has certified that it adheres t the Privacy Shield Principles f Ntice, Chice, Accuntability fr Onward Transfer, Security, Data Integrity and Purpse Limitatin, Access, and Crrectin, Enfrcement and Dispute Reslutin. If there is any cnflict between the plicies in this privacy plicy and the Privacy Shield Principles, the Privacy Shield Principles shall gvern. T learn mre abut the Privacy Shield prgram, and t view ur certificatin page, please visit T view ur certificatin under Privacy Shield, please visit Yu may direct any cmplaints pertaining t ur cllectin and/r use f yur infrmatin t us at: security@yurcause.cm r by mail at YurCause Security Office 6111 West Park Blvd. Suite 1000 Plan Texas, In cmpliance with the EU-U.S. Privacy Shield Principles, YurCause cmmits t reslve cmplaints abut yur privacy and ur cllectin r use f yur persnal infrmatin within 45 days. If yu are unsatisfied with the reslutin f yur cmplaint, please cntact the independent recurse mechanism listed belw: HR Data Recurse Mechanism If a cmplaint invlving HR data remains unreslved, individuals shuld cntact the state r natinal data prtectin r labr authrity in the jurisdictin where the individual wrks fr reslutin. YurCause cmmits t cperate with the cmpetent Eurpean Unin Data Prtectin Authrities (DPAs) and cmply with the advice given by such authrities with regard t data transferred frm the EU including human resurces data transferred frm the EU in the cntext f the Services ffered by YurCause. In the event that YurCause r the DPAs determine that YurCause did nt cmply with this Plicy r Privacy Shield principles, YurCause will take apprpriate steps t address any adverse effects and t prmte future cmpliance, cmply with any directive given by the DPAs where the DPAs have determined that YurCause shuld take specific remedial r cmpensatry measures fr the benefit f individuals affected by any nncmpliance with the Privacy Shield principles. A listing f all EU Data Prtectin Authrities ( DPAs ) is lcated at: Nn-HR Data Recurse Mechanism YurCause has cmmitted t refer unreslved privacy cmplaints under the EU-U.S. Privacy Shield Principles t PrivacyTrust, an alternative dispute reslutin prvider. If yu d nt receive timely acknwledgment f yur cmplaint frm us, r if we have nt addressed yur cmplaint t yur satisfactin, please cntact r visit PrivacyTrust s dispute reslutin prtal at fr mre infrmatin r t file a cmplaint. The services f the PrivacyTrust are prvided at n cst t yu. Finally, as a last resrt and in limited situatins, a binding arbitratin ptin will als be made available t EU individuals t address residual cmplaints nt reslved by any ther means. i. Scpe The EU-U.S. Privacy Shied Framewrk applies t all persnal infrmatin received by YurCause and emanating frm the EEA and frm Switzerland (cllectively EU Persnal Data ), in any frmat, including electrnic, paper r verbal. This plicy is applicable t all YurCause entities in the United States.

10 ii. Privacy Principles The privacy principles in this Plicy have been develped based n the EU-U.S. Privacy Shield Framewrk and the Swiss U.S. Privacy Shield Framewrk. iii. Ntice YurCause is subject t the investigatry and enfrcement pwers f the Federal Trade Cmmissin (FTC). YurCause may be required t disclse an individual s persnal infrmatin in respnse t a lawful request by public authrities, including t meet natinal security r law enfrcement requirements. Where YurCause cllects persnal infrmatin directly frm individuals in the EEA, it will infrm them abut the purpses fr which it cllects and uses persnal infrmatin abut them, the types f nn agent third parties t which YurCause disclses that infrmatin, the chices and means, if any, YurCause ffers individuals fr limiting the use and disclsure f persnal infrmatin abut them, and hw t cntact YurCause. Ntice will be prvided in clear and cnspicuus language when individuals are first asked t prvide persnal infrmatin t YurCause, r as sn as practicable thereafter, and in any event befre YurCause uses r disclses the infrmatin fr a purpse ther than that fr which it was riginally cllected. Where YurCause receives persnal infrmatin frm its subsidiaries, affiliates r ther entities in the EEA, it will use and disclse such infrmatin in accrdance with the ntices prvided by such entities and the chices made by the individuals t whm such persnal infrmatin relates. iv. Chice YurCause may ffer individuals the pprtunity t chse (pt-ut) whether their persnal infrmatin is (a) t be disclsed t a nn-agent third party, r (b) t be used fr a purpse ther than the purpse fr which it was riginally cllected r subsequently authrized by the individual. Fr sensitive persnal infrmatin, YurCause will give individuals the pprtunity t affirmatively and explicitly (pt-in) cnsent t the disclsure f the infrmatin t a nn-agent third party r the use f the infrmatin fr a purpse ther than the purpse fr which it was riginally cllected r subsequently authrized by the individual. YurCause will prvide individuals with reasnable mechanisms t exercise their chices. v. Data Integrity YurCause will use persnal infrmatin nly in ways that are cmpatible with the purpses fr which it was cllected r subsequently authrized by the individual. YurCause will take reasnable steps t ensure that persnal infrmatin is relevant t its intended use, accurate, cmplete, and current. vi. Onward Transfers t Agents and Third Parties In cases YurCause leverages the use f nward transfer t third parties f Persnal EU Data, YurCause is ptentially liable and will btain assurances frm its agents that they will safeguard EU Persnal Data cnsistently with this Plicy. Examples f apprpriate assurances that may be prvided by agents include: a cntract bligating the agent t prvide at least the same level f prtectin as is required by the relevant Privacy Principles, certificatin by an agent, r being subject t anther Eurpean Cmmissin r Swiss FDPIC adequacy finding (e.g., cmpanies lcated in Canada). Where YurCause has knwledge that an agent is using r disclsing persnal infrmatin in a manner cntrary t this Plicy, YurCause will take reasnable steps t prevent r stp the use r disclsure.

11 vii. Access and Crrectin Upn request, YurCause will grant qualified and apprved individuals reasnable access t EU Persnal Data that it hlds abut them. In additin, YurCause will take reasnable steps t permit individuals t crrect, amend, r delete infrmatin that is demnstrated t be inaccurate r incmplete. viii. Security YurCause will exercise generally acceptable industry standards cupled with cmmercially reasnable precautins t prtect EU Persnal Data in its pssessin frm lss, misuse and unauthrized access, disclsure, alteratin and destructin. ix. Enfrcement YurCause will cnduct cmpliance audits f its relevant privacy practices t verify adherence t this Plicy. Any emplyee that YurCause determines is in vilatin f this plicy will be subject t disciplinary actin up t and including terminatin f emplyment. x. Limitatin n Applicatin f Principles EU Persnal Data will nt be prcessed in a way that is incmpatible with r materially different frm the purpses fr which it has been cllected r subsequently authrized by the individual. Reasnable steps will be taken t ensure that EU Persnal Data is reliable fr its intended use, accurate, cmplete and current. Further, all EU Persnal Data will be retained nly fr as lng as it serves the purpses fr which it was cllected r subsequently authrized by the individual. Adherence by YurCause t all the afrementined Plicies and Principles may be limited (a) t the extent required t respnd t a legal r ethical bligatin; (b) t the extent necessary t meet natinal security, public interest r law enfrcement bligatins; and (c) t the extent expressly permitted by an applicable law, rule r regulatin. EU GENERAL DATA PROTECTION REGULATION ( GDPR ) YurCause prcesses persnal data f data subjects in the EU and ffers gds and services t EU natural persns. As such, all prcessing f EEA Persnal Data is perfrmed in accrdance with privacy rights and regulatins fllwing the EU Directive 95/46/EC f the Eurpean Parliament and f the Cuncil f 24 Octber 1995 (the Directive). Frm May 25th, 2018, the Directive and lcal legislatin based n the Directive will be replaced by the Regulatins (EU) 2016/679 f the Eurpean Parliament and f the Cuncil f April 27, 2016 n the prtectin f EEU natural persns with regard t the prcessing f Persnal Data. YurCause agrees t cmply with the General Data Prtectin Regulatin ( GDPR ) and assciated Mdel Cntract Clauses fr the transfer, handling, cntrl, strage, and utilizatin f yur data. The GDPR was designed t harmnize data privacy laws acrss Eurpe, t prtect and empwer all EU citizens data privacy and t reshape the way rganizatins acrss the regin apprach data privacy. If there is any cnflict between the plicies in this Privacy Plicy and the GDPR, the GDPR shall gvern. T learn mre abut the GDPR, please visit Yu may direct any cmplaints pertaining t ur cllectin and/r use f yur infrmatin t us at: security@yurcause.cm r by mail at YurCause Security Office 6111 West Park Blvd. Suite 1000 Plan, Texas,

12 SOCIAL MEDIA WIDGETS The Sites may include Scial Media Features, such as the Facebk Like buttn, and Widgets, such as the Share This buttn r interactive mini-prgrams that run n ur website. These Features may cllect yur Internet prtcl address, which page yu are visiting n ur website, and may set a ckie t enable the Feature t functin prperly. Scial Media Features and Widgets are either hsted by a third party r hsted directly n ur website. Yur interactins with these Features are gverned by the privacy statement f the cmpany prviding them. LINKS TO OTHER SITES Our Services, frm time t time, may cntain links t ther websites. If yu chse t click n anther third-party link, yu will be directed t that third party s website. The fact that we link t a website is nt an endrsement, authrizatin r representatin f ur affiliatin with that third party, nr is it an endrsement f their privacy r infrmatin security plicies r practices. We d nt exercise cmplete cntrl ver third party websites. These ther websites may place their wn ckies r ther files n yur cmputer, cllect data r slicit persnal infrmatin frm yu. Other sites fllw different rules regarding the use r disclsure f the persnal infrmatin yu submit t them. We encurage yu t read the privacy plicies r statements f the ther websites yu visit. OUR POLICY TOWARD CHILDREN The Site and Services are nt directed t children under 13. We d nt knwingly cllect persnally identifiable infrmatin frm children under 13. If a parent r guardian becmes aware that his r her child has prvided us with Persnal Infrmatin withut their cnsent, he r she shuld cntact us. If we learn that we have inadvertently cllected the persnal infrmatin f a child under 13, r equivalent minimum age depending n jurisdictin, we will take steps t delete the infrmatin as sn as pssible. BUSINESS TRANSFERS In cnnectin with a business transactin where an entity acquires all r substantially all f the business r assets f YurCause, whether by merger, acquisitin, r rerganizatin r in the event f bankruptcy, YurCause may transfer t r therwise share with such acquiring entity, all data assciated with the prduct and services prvided by YurCause, subject t any agreements between the Cmpany and YurCause. CHANGES TO THIS PRIVACY POLICY This Privacy Plicy is effective as f April 2018 and will remain in effect except with respect t any changes in its prvisins in the future, which will be in effect immediately upn validatin. YurCause reserves the right t revise r update this Privacy Plicy at any time, and yu agree t be bund by thse revisins r updates. YurCause will ntify yu f any changes t the Privacy Plicy by psting the revised r updated Privacy Plicy and its "Last revised" date n the Sites. Yur use f the Sites r Services thereafter cnstitutes yur agreement t and acceptance f the Privacy Plicy and its revisins r updates. Yu shuld peridically read the Privacy Plicy t learn f any revisins r updates. This Privacy Plicy is incrprated as part f the Terms and Cnditins that apply with respect t yur use f the Sites and Services. If yu d nt agree t the terms and cnditins f this Privacy Plicy, including having yur

13 infrmatin used in any f the ways described in this Privacy Plicy, d nt prvide us with yur infrmatin and d nt use the Sites r Services. This Privacy Plicy des nt apply t infrmatin yu may chse t prvide t YurCause that des nt display r link t this Privacy Plicy r that des nt have this Privacy Plicy prminently displayed at the pint f cllectin. By prviding us yur infrmatin yu acknwledge that yu have read this Privacy Plicy and that yu cnsent t YurCause 's privacy practices as described in this Privacy Plicy. Yu further affirm yur cnsent by submitting cntent r materials t us thrugh ur Sites. This Privacy Plicy is nt intended t and des nt create any cntractual r ther legal right in r n behalf f any persn. The infrmatin yu prvide t YurCause when yu becme a member is als gverned by the terms and cnditins f yur membership. In the event f a cnflict between this Privacy Plicy and any term(s) f yur membership, the terms f yur membership will gvern. Yu are advised t cnsult this plicy regularly fr any changes. Please nte that a ntice will be psted n YurCause s web pages whenever this Privacy Plicy is changed in a material way. REPORTS, CONTACT AND ELECTRONIC COMMUNICATIONS We peridically prepare analyses and reprts reflecting visitr and member use f the Services. In preparing these reprts, we may cmbine and analyze the persnal infrmatin yu prvide t us with infrmatin frm ther surces. Hwever, these reprts will nly include aggregate infrmatin abut visitrs and Authrized Users. The infrmatin in these reprts will nt identify individuals. Any business partner with whm such reprts may be shared will als nt be able t cntact yu frm the infrmatin cntained in the reprts. By prviding yur infrmatin n ur Sites and/r registering t becme a member yu agree that we can cmmunicate with yu electrnically regarding any legal, regulatry, technical, security, privacy, administrative r cnsumer ntificatin bligatin relating t yur use f the Sites r regarding yur membership. We may use yur address t cnfirm yur request, t send yu ntice f payments, t send yu infrmatin abut changes t ur prducts and services, and t send ntices and ther disclsures as described abve r as required by law. Generally, users cannt pt-ut f these cmmunicatins, but they will be primarily infrmatinal in nature rather than prmtinal. If yu have any specific questins abut this Privacy Plicy, yu can cntact YurCause Security Office. YurCause Security Office YurCause, LLC 6111 W. Plan Parkway Suite 1000YC Plan, Texas security@yurcause.cm Update Lg: April 2017 April 2018