Last updated: August 24, 2018
- for the purposes of the EU General Data Protection Regulation 2016/679 (the "GDPR"), the data controller is ImpactGuru.com and can be reached at the address set out at Contacting Impact Guru below;
- "information" covers all personal data processed by us which means "information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly; and
Information We Collect
As further described below, when you use or otherwise access the Services, we may collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from your browser or device.
Information That You Provide Directly to Us
We collect information from you (including, but not limited to, your name, email address, and location) when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, provide us with feedback, register for access to the Services, or use certain Services.
You may also provide us with information relating to third parties - including information stored in your email and mobile device address books - such as, without limitation, names, email addresses, and phone numbers of your contacts (collectively, 'Third-Party Data'). The Services may request your permission to access such Third-Party Data.
You may also provide us with special categories of personal data under the GDPR (also known as sensitive data) about yourself and/or third parties, such as health information. When you provide such information, we will seek your explicit consent unless it is being published in relation to your campaign.
We collect this information for the purposes described below in the section entitled, Our Use of Information Collected. While you are under no obligation to directly provide us with such information, should you choose to withhold such information, we may not be able to provide you with some or all of the Services.
If you provide 'personal data' you acknowledge and agree that such personal data may be transferred from your current location to the offices and servers of Impact Guru and the authorized third parties referred to herein located in the United States or India.
Our Services may include online chats and message boards. Please remember that any information that is disclosed in these areas becomes public information for both us and other users to use and share. Please be considerate and respectful of others while using the community to share your opinions. We reserve the right, but do not have the obligation, to review and monitor such posting or any other content on our Services, and to remove postings or content that may be viewed as inappropriate or offensive to others.
Information That is Passively or Automatically Collected
Device & Usage Information:
When you interact with Impact Guru through the Services, we automatically receive and store certain information from devices that you use to access the Services. This information is collected passively using various technologies, and includes the type of internet browser or mobile device you use, any website from which you have come to the Services, your operating system, and may include location data through an IP address that identifies the city and state where you logged into the Platform or your precise geo-location if you have permitted your mobile device to provide that information to us. Impact Guru may store such information itself or such information may be included in databases owned and maintained by Impact Guru affiliates, agents or service providers.
In an ongoing effort to better understand and serve the users of the Services, Impact Guru often conducts research on its customer demographics, interests and behavior based on information we collect. We may de-identify and/or aggregate the information collected through the Services for research purposes or any other purposes, and we may share this data with our affiliates, agents, business partners, or other third parties.
When you use the Services to organize a fundraising campaign, the Services may request that you provide your city or town and state or province of residence. Please keep in mind that other users of the Services may be able to view your city or town and state or province of residence in connection with the campaign, if it is made available within Impact Guru's Public Search Directory. We may also use your location information in an aggregate way, as described above in the "Aggregated Data" section.
Cookies and Other Electronic Technologies:
When you interact with the Services, we try to make that experience simple and meaningful. When you visit our Platform, our web server sends a cookie to your computer or mobile device. Cookies are small pieces of information that are issued to your computer or mobile device when you visit a website or access or use a mobile application, and that store and sometimes track information about your use of the Platform. 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 Platform and will last longer.
Some of the cookies used by the Platform 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.
You may also consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe's website. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
If you are accessing our Services through a mobile device, you can also update your privacy settings on your device by setting the "Limit Ad Tracking" and Diagnostics and Usage setting property located in the settings screen of your Apple iPhone or iPad, or by resetting your Android ID through apps that are available in the Play Store. You can also limit information collection by uninstalling the App on your device and you can use the standard uninstall process available as part of your device for this purpose.
Information From Social Networking Services
You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Platform); you acknowledge that if you choose to use this feature, your friends, followers, and subscribers on any Social Networking Services you have enabled will be able to view such activity.
Our Use of Information Collected
We may also use the information collected from the 'Information We Collect' section, such as device identifiers and MAC addresses, 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). For the purposes of the GDPR, we may use your information in the above ways as this is necessary: (i) to fulfil our obligations under our contract with you or in order to take steps at your request prior to entering into a contract; (ii) for our legitimate interest to maintain our relationship with you or protect you and us against fraud; or (iii) to comply with legal obligations.
Impact Guru may use the information collected through the Services to contact you about services we believe will be of interest to you. In some cases, we will seek your permission. In each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. If you opt out of receiving marketing communications or other information we think may interest you, as discussed below, we may still send you emails about your account or any Services you have requested or received from us.
We may also use data collected through the Services to send communications relating to the Services, in accordance with applicable laws. For example, we may send periodic emails to registered users of the Services relating to their recent interactions with the Services, such as donating to a campaign or "hearting" a campaign. Also, if you use any feature of the Services permitting you to communicate with third parties (such as to refer a third party to the Services or to communicate with them regarding a campaign or a donation), either by submitting Third-Party Data to the Services or otherwise permitting the Services to automatically access Third-Party Data in your possession, you acknowledge and agree that you have the authority of the relevant third party for us to access and use the relevant Third-Party Data and that you have notified these third parties and informed them how their information is collected and used by Impact Guru to provide the Services. We reserve the right to identify you as the person who has made the referral in any messages that are sent to them. We may use Third-Party Data to (1) contact such third party using the Third-Party Data provided, and/or (2) provide you with an editable template message designed to facilitate communication between you and such third party through the Services. In addition to sending the foregoing communications, we may also send reminders or related messages to you and to third parties on your behalf from time to time where permitted by applicable law. In each case, any such communications sent to third parties using Third-Party Data will provide a means to "opt-out" of receiving further communication of the same nature.
Mobile Services: If you access the Services through a mobile device, you agree that we may communicate with you regarding Impact Guru by SMS, MMS, text message, Whatsapp or other electronic means to your mobile device. In the event you change or deactivate your mobile telephone number, you agree to promptly update your Impact Guru account information to ensure that your messages are not misdirected. Please note that your wireless service carrier's standard charges, data rates, and other fees may apply where you access the Services through a mobile device. In addition, downloading, installing, or using certain Services on a mobile device may be prohibited or restricted by your carrier, and not all Services may work with all carriers or devices. By using the Services on a mobile device, you agree that we may communicate with you regarding Impact Guru by SMS, MMS, text message, or other electronic means to your mobile device. In the event you change or deactivate your mobile telephone number, you agree to promptly update your Impact Guru account information to ensure that your messages are not misdirected.
Our Disclosure of Information Collected Through the Services
There are certain circumstances in which we may share information collected through the Services with certain third parties without further notice to you, as set forth below:
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, similar event, or steps taken in anticipation of such events (e.g., due diligence in a transaction), user information may be part of the transferred assets.
Agents, Consultants, Vendors and Related Third Parties:
Impact Guru, like many businesses, sometimes hires other companies to perform certain business-related functions on its behalf, and we may provide access to or share your information with these companies so they can perform services for us. Examples of such functions include marketing, mailing information, data storage, security, fraud preventions, payment processing, legal services, and maintaining databases.
If you donate to a fundraising campaign, we may share your name, email address and other information you've provided in connection with your donation with the campaign organizer, who may contact you.
We may share your information in the event that you consent to the sharing of your information.
Aggregate and/or De-Identified Information
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.
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.)
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.
Our Services are not designed for use by individuals under the age of 13(or 16 in Europe). If you are under the age of 13(or 16 in Europe), please do not use the Services and/or submit any information through the Services. If you have reason to believe that a child under the age of 13(or 16 in Europe) has provided personal information to Impact Guru through the Services, please contact us at firstname.lastname@example.org, and we will delete that information from our databases to the extent required by law.
Links to Other Websites
Impact Guru has implemented technical and organizational security measures to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, limiting access to information only to employees and authorized service providers who need to know such information for the purposes of this Privacy Notice. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information to Impact Guru via the Internet.
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
Retention of your information
We will only retain the information for as long as necessary for the purpose for which that information was collected and to the extent permitted or required by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take step to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies.
Access to Information
You may access and correct certain information about you by visiting the "Account Settings" portion of our Platform. You may also request in writing copies of personal information about you held by us. If that information is inaccurate, please let us know and we will endeavor to make the necessary amendments, erase, or block the relevant information as you request. For more information on your rights if you are in Europe, please see the "Users in Europe" section below.
Users in Europe
- Access. You have the right to request a copy of the information we are processing about you.
- Rectification. You have the right to have incomplete or inaccurate information that we process about you rectified.
- Deletion. You have the right to request that we delete information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to restrict our processing of your information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
- Portability. You have the right to obtain information we hold about you in a structured, electronic format, and to transmit such data to another data controller, where this is (a) information that you have provided to us, and (b) if we are processing that data solely on the basis of your consent or to perform a contract with you.
- Objection. Where the legal basis for processing your information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
- Withdrawing consent. If you have consented to our processing of your information, you have the right to withdraw your consent at any time, free of charge. This includes where you wish to opt out from marketing messages.
You can make a request to exercise any of these rights in relation to your information by sending the request to us at the email address or mailing address set forth under Contacting Impact Guru . For your own privacy and security, at our discretion, we may require you to provide your identity before providing the requested information. Please note that Impact Guru may take up to 30 days to fulfill such requests.
You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. A list of local data protection authorities in European countries is available here.
Other Terms and Conditions
Data Protection Officer
In addition, Impact Guru appoints Dheeraj Bansal (email@example.com) as a Data Protection Officer (DPO), who will assume the following role
- Educating the company and employees on important compliance requirements
- Training staff involved in data processing
- Conducting audits to ensure compliance and address potential issues proactively
- Serving as the point of contact between the company and GDPR Supervisory Authorities
- Monitoring performance and providing advice on the impact of data protection efforts
- Maintaining comprehensive records of all data processing activities conducted by the company, including the purpose of all processing activities, which must be made public on request
- Interfacing with data subjects to inform them about how their data is being used, their rights to have their personal data erased, and what measures the company has put in place to protect their personal information
Contacting Impact Guru
You may contact us as follows:
Impact Guru Technology Ventures Private Limited
B 401, Pramukh Plaza,
Cardinal Gracias Road,
Chakala, Andheri (East),
Mumbai - 400059, India.