VISA® GIVING GATEWAY PRIVACY POLICY

OVERVIEW

Thank you for using the Visa® Giving Gateway (“Giving Gateway”). Giving Gateway is an online service provided by Visa U.S.A. Inc. (“Visa,” “us,” “we” or similar pronoun) through which Visa cardholders can make donations with their Visa card to nearly 1 million IRS qualified §501(c)(3) public charities that are described in §§509(a)(1) and 509(a)(2) through one online portal. Giving Gateway is powered by Blackbaud, Inc. (“Blackbaud”), a third party service provider to Visa. Donations made at Giving Gateway are solicited, collected, received and processed by Renaissance Charitable Foundation Inc. (“RCF”), a public charity as defined in §§501(c)(3), 509(a)(1) and 170 (b)(1)(A)(vi) of the Internal Revenue Code and a third party to Visa, who in substantially all cases will grant the amounts donated (less an administrative fee) to the charity recommended by the donors (each, a “Benefiting Charity”). Giving Gateway is described in more detail in the Visa Giving Gateway Terms of Service. We highly value and respect the privacy of the personal information we obtain from you in connection with your use of Giving Gateway, including your name, email address, billing address, Visa card account numbers and other information that can be used to individually identify you (collectively, “Personal Information”) and we have created this privacy policy (the “Privacy Policy”) to inform you about how we collect, use and share your Personal Information, and our privacy practices in general. As used in this Privacy Policy, the term “Giving Gateway” will also include the Giving Gateway website (“Website”).

As described in this Privacy Policy, Visa uses information that we obtain from you and other third parties in connection with your use of Giving Gateway to participate in and take advantage of the various Giving Gateway features and functionality, for our own internal analysis, and to make Giving Gateway and our other programs and features more useful and interesting to you.

A special note regarding Visa and Giving Gateway

Please note that Visa does not collect, use or share Personal Information in connection with Giving Gateway for purposes of soliciting contributions from the public nor will Visa collect, use or share Personal Information from the public for purposes of making grants for the benefit of recommended charities or charitable causes. Only RCF is and will be collecting, using and sharing Personal Information in connection with Giving Gateway to make such solicitations and grants. RCF will retain Blackbaud to create, maintain and host certain online portions of Giving Gateway.

A special note about minors

Giving Gateway is not available to minors below the legal age of majority in their jurisdiction and Visa does not knowingly collect Personal Information from such minors.

Applicability of this Privacy Policy

This Privacy Policy applies solely to information collected online in connection with Giving Gateway. Without limiting the foregoing, this Privacy Policy does not apply to information that may be collected by Visa through any other Visa websites or services.

NOTICE

Information Visa collects at Giving Gateway

You Personal Information may be collected in a number of ways in connection with Giving Gateway, including, without limitation, as follows:

When you set up a Giving Gateway account (“Account”), we will collect the Personal Information you voluntarily choose to provide, such as your name and email address.
When you opt-in to receiving promotional communications from Visa and its affiliates, we collect your email address or other contact information.
When you ask us a question, we collect an email address or other contact information you choose to provide.
When you choose to participate in surveys, we may collect your email address or other relevant contact information.
When you initiate a forward-to-a-friend email.
We collect information you voluntarily submit when participating in one of our various services, programs or surveys.

How Visa uses your information

To generally provide the features and functionality of Giving Gateway to you.
To send forward-to-a-friend emails on your behalf.
To identify you as the sender of forward-to-a-friend emails.
To send you updates about Giving Gateway via email and other media.
To send you promotional offers from Visa and its affiliates, if you opt-in to such communications.
To respond to questions and comments.
To perform donor analytics and modeling.
To improve, enhance and tailor Giving Gateway for you, and to improve and enhance the overall Giving Gateway experience for all users of Giving Gateway.To enhance fraud prevention and for purposes of regulatory compliance.

To whom Visa discloses your information

Visa may disclose to third parties all categories of Personal Information that it collects as follows:

Provision of Services: We disclose your Personal Information to third parties where necessary to provide Giving Gateway to you.
At Your Request: We disclose your Personal Information to a third party whenever you request us to do so. For example, when you opt-in to provide Personal Information to your recommended Benefiting Charity, we will share your Personal Information pursuant to your request.
Forward-to-a-friend emails: We disclose your Personal Information to third parties when we transmit a forward-to-a-friend email on your behalf.
Business transfers: If a third party acquires all or substantially all of Visa’s assets, your Personal Information, aggregated information, and any other information that we have collected in connection with Giving Gateway may be transferred to such third party as part of our business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered one of our assets and may be sold or transferred to third parties.
Disclosure of Personal Information for legal purposes and protection of Visa and others: We reserve the right to share your Personal Information with third parties if required to do so by law, or if we believe such action is necessary in order to: (1) conform to the requirements of the law or comply with legal process served upon us; (2) protect or defend our legal rights or property, Giving Gateway, or our users; or (3) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the Giving Gateway Terms of Service.
Service Providers: We use third-party service providers, such as Blackbaud, to perform certain technical services on our behalf, such as: hosting Giving Gateway; processing, storing, maintaining and transmitting data; processing and fulfilling email and other promotional campaigns; and providing marketing assistance, web analytics and data analysis. We may provide your Personal Information to these third-party service providers when the information is necessary or helpful for them to perform their duties. These third-party service providers are contractually restricted from using Personal Information for any other purpose and required to comply with all applicable laws with respect to the Personal Information they receive.
Government Agencies: We will disclose your Personal Information to third parties if required to do so by law,
As Otherwise Permitted By Law. We may disclose your Personal Information to third parties as otherwise permitted by applicable law.

A special note about RCF and your donations

RCF, not Visa, collects information regarding your proposed donation, including, without limitation, the name of your recommended Benefiting Charity, amount of your donation, Visa payment card information and associated Personal Information you provide in connection with donations made at Giving Gateway. RCF will collect, use, store and share the Personal Information you supply at Giving Gateway solely for the purposes of receiving and processing your donation and in substantially all cases paying the amount of each donation (less an administrative fee) to your recommended Benefiting Charity. RCF may share your Personal Information with its service providers (including, without limitation, Blackbaud) in furtherance of processing your donations. Except as set forth in this Privacy Policy, RCF’s service providers are contractually restricted from using Personal Information for any other purpose than to carry out services for RCF. RCF may also share your Personal Information in connection with business transfers, for regulatory compliance purposes, for legal purposes and protection of RCF and others, to government agencies and as otherwise permitted by law. RCF may use and share information it collects on an aggregate, non-personally identifiable basis for purposes of analytics, benchmarking and other lawful purposes. Any information collected by RCF may be shared and/or made available to Visa.

Automatically collected non-Personal Information

When you use Giving Gateway, we also may collect certain standard information from your browser and personal computer that websites often collect, such as your IP address, your browser information (including browser type, capabilities and language), your operating system and the date and time you accessed Giving Gateway. We also capture the general geographic area from which the visit came and the paths taken as you move from one website or webpage to another website or webpage (i.e., your "click stream" activity). We may group some or all of this information, along with other non-Personal Information collected by or provided to us, into aggregate data in order to describe the use of Giving Gateway by our users to our existing or potential business partners, sponsors, advertisers or other third parties, or in response to a government request. We may also group demographic information that we collect from Giving Gateway users into aggregate data for the same purposes. We reserve the right to use and share any such non-Personal Information with third parties for any lawful purpose.

Visa does not typically associate such non-Personal Information with any individual. However, to the extent Visa associates your Personal Information with non-Personal Information within our database, we will treat all the associated information as Personal Information under this Privacy Policy. Except as noted in this Privacy Policy, we do not share this associated information with third parties.

Browsing and the use of cookies, Web beacons and other tracking technologies

Visa uses cookie technology as part of Giving Gateway’s statistical reporting and for other purposes related to making Giving Gateway available to you. A cookie is a small piece of information sent by a website that is saved on your hard disk by your computer's browser. It holds information a website may need to personalize your experience (such as, rotating images on the home page of the website). We also utilize cookies to identify if you are logged into your Account.

If you prefer, you can configure your browser to reject all cookies, or to notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie and privacy preferences. However, if you reject cookies, your use of Giving Gateway will be materially impaired or may altogether preclude your use of Giving Gateway.

A Web beacon is an electronic image, also called a single-pixel or clear GIF, placed in the code of a webpage or in emails. The Website uses Web beacons to track traffic patterns of users as they navigate from one page to another. This information lets us tune and improve our users’ browsing experience. As with cookies, the information that Web beacons collect is aggregated, anonymous “click stream” data, and is not associated with you as an individual.

We also use Web beacons through a third party website analytics provider, as well as standard Web server log files, to help us count visitors and evaluate the Website's technical capacity. This information tells us how many people visit the Website, and helps us decide how to arrange pages in the most user-friendly way. This also helps us keep the Website browser-friendly and more useful to our users. We record information on Website traffic, but not on individual visitors to the Website, so no Personal Information about you will be kept or used in connection with such web analytics.

Forward-to-a-friend feature

We may offer you the opportunity to email information about Giving Gateway and your Benefiting Charities to your family and friends through the forward-to-a-friend feature. If you choose to use our forward-to-a-friend feature, we will collect the name and email address of the intended recipient in order to send emails on your behalf. We may also use your name and email address in order to identify you as the sender of the emails. Visa does not store the name or email address of any designated family member or friend (except in the case where the friend independently registers for an Account); the data is collected for the sole purpose of sending one-time emails to your family and friends on your behalf.

Surveys

From time to time, Visa may conduct surveys through the Website. If you choose to participate—unless otherwise noted in the applicable terms and conditions or disclaimers—we may use the information you provide in connection with the survey, including use of your responses as a part of survey results, in the aggregate, on the Website. Except where necessary to administer a survey, unless you have otherwise agreed or unless required by law, we will not share or publish any response you give connected to your name or address. We will hold these responses only as anonymous statistics.

Third party websites, content and resources

Please be aware that when you are using Giving Gateway, you could be directed via hyperlinks or other means to third party websites, content and resources, including websites of companies that participate in Giving Gateway (for example, the websites for Blackbaud and RCF). Likewise, when you opt-in to provide your Personal Information to Benefiting Charities, your Personal Information will be shared with those Benefiting Charities. The privacy policies of these third party websites, content and resources may be very different from this Privacy Policy and these third party websites, content and resources may send their own cookies to visitors, collect data or solicit and use your Personal Information in ways different than set forth in this Privacy Policy. We are not responsible for the privacy practices of the providers of these other websites, content and resources and cannot guarantee the security of any of your Personal Information collected, used or shared there.

Our policy regarding selling or renting of Personal Information

It is our policy not to sell or rent your Personal Information to any third parties, except in the event of a bankruptcy or reorganization, or a sale of all or substantially all of our assets, as further provided in this Privacy Policy.

International Use

Please note that Giving Gateway is only available to legal residents of the 50 United States or the District of Columbia. Those residing outside of the foregoing jurisdictions are not permitted to use Giving Gateway.

CHOICE

How you can decide what communications you'll receive from Giving Gateway

Giving Gateway users can opt-out from promotional communications from Giving Gateway by using the unsubscribe link within a promotional email or by visiting the “My Giving Gateway” page and editing your preferences. Please note that regardless of whether you opt-out to receive promotional communications, you cannot opt-out of certain non-promotional communications from Giving Gateway (such as donation receipts, information regarding updates to the Website and other required disclosures) without cancelling your Account.

ACCESS AND DATA RETENTION

How to update or correct certain of your Personal Information

For those cardholders setting up an Account, you can access and modify certain Personal Information associated with an Account stored with Giving Gateway, such as your name and email address, by logging into Giving Gateway and visiting the “My Giving Gateway” page.

You can also modify your Giving Gateway preferences (such as opting-out from receiving promotional and other offers from Visa) by logging into Giving Gateway and visiting your “My Giving Gateway” page. Please note that if you opted-in to provide your Personal Information to a Benefiting Charity, you must contact such Benefiting Charity to understand what level of control you have over Personal Information so provided. Visa shall have not liability for any collection, use, sharing and security of your Personal Information provided to any Benefiting Charity.

If you send us a request to cancel or delete your Account, we will request the service provider flag your Account on its servers as an inactive account, but the Account information will not be deleted and will be available to you at a future date if you choose to re-enroll in Giving Gateway. In addition, Visa will retain certain information (including Personal Information) provided to us indefinitely for the following or other lawful purposes:

Auditing purposes
Troubleshoot problems
Assist with investigations
Enforce the Giving Gateway Terms of Service
Comply with legal requirements

SECURITY

Security of your Personal Information

The security of your Personal Information is very important to us, and we are committed to protecting the Personal Information we collect. While we cannot guarantee absolute security of your Personal Information, Visa requires that Blackbaud use firewalls and Secure Socket Layers for sensitive Personal Information collected from you when it is being communicated. We also require that Blackbaud and RCF restrict access to Personal Information to those employees, agents and service providers who need to know or access the information in order to provide you with Giving Gateway. We also require Blackbaud maintain physical, electronic and procedural safeguards that comply with applicable federal privacy and data security laws and regulations to guard your Personal Information. Unfortunately, no transmissions or data available through the Internet can be 100% secure and, accordingly, we cannot guarantee or warrant the security of any Personal Information or other information you provide to us. As with any transmission over the Internet, such data may be accessed by unauthorized parties.

PRIVACY POLICY UPDATES

This Privacy Policy was updated on the “Last Updated” date noted above. We continually strive to find new ways to enhance Giving Gateway and Visa reserves the right to change, modify, or amend this Privacy Policy from time to time to reflect changes in our privacy practices. You are encouraged to review this Privacy Policy periodically and to check the “Last Updated” date at the top of this Privacy Policy for the most recent version to inform yourself about how your Personal Information is collected, used and shared when you use Giving Gateway. To the fullest extent under applicable law, your use of Giving Gateway after the “Last Updated” date means you are subject to the Privacy Policy then in effect.

CUSTOMER SERVICE AND RECOURSE

How to contact Visa regarding your privacy concerns and questions If you have any questions, comments, criticisms, or complaints about this Privacy Policy, our privacy practices, or the way either of them affects you, please feel free to email us at visagivinggatewayprivacy@blackbaud.com. Do not use this contact information for non-privacy related matters.

Disputes

Should you have a dispute regarding this privacy policy, we will resolve it and take any remedial action as we reasonably determine in our discretion and in accordance with applicable laws. Disputes regarding this Privacy Policy are subject to the Giving Gateway Terms of Service.

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