September 5, 20140 CommentsJenna Buckle
Welcome to the website of EverTrue, Inc. (“EverTrue”, “we”, “us” and/or “our”) www.evertrue.com (the “Site”). EverTrue offers hosted Software as a Service platform to colleges and universities (“Customers”) that contract with us for intelligence-based fundraising and related services. Our related products and services include mobile and other applications, including EverTrue Platform, EverTrue Alumni Community, EverTrue Online Giving, EverTrue Relationship Management, EverTrue Volunteer Management and Console (collectively, the “Services”). Through our advanced technologies we help Customers identify potential donors and create fundraising campaigns, by using alumni data such as employment history, expertise, job title, age, location and social media activities and combining it with information from surveys and publicly available data as described below. We also offer a mobile app (“App”) for individual users of EverTrue Alumni Community (“App Users”) to identify and network with fellow alumni and for individual users of EverTrue Platform, EverTrue Online Giving, EverTrue Relationship Management and EverTrue Volunteer Management to identify potential donors and create fundraising campaigns on their mobile devices.
Where we provide the Services under contract with our Customers, that Customer controls the information processed by the Services. This information, collected on behalf of our Customers, includes data collected from our Customers’ Advancement Officers or employees who hold similar positions, and information about alumni and their relatives, and donors.
1. INFORMATION WE COLLECT
In operating our Services, we collect information that alone or in combination with other information can be used to identify an individual (“Personal Data”), described below.
Account Information: We collect information about you when you register for an account (such as usernames, email address and billing information, phone number), create or modify your profile, set preferences.
Information you provide in relation to inquiries, surveys or customer support: We collect Personal Data that you voluntarily give us when you contact us with inquiries, engage with our chat bot on the Site, respond to one of our surveys, contact our customer support regarding a problem you are experiencing with the Services.
App Users: When you download and use our App we will automatically collect certain information, described under the Automatically Collected Data section below.
Site Visitors: We collect information that Site Visitors enter on our Site or send to us electronically, for example, when completing a web form to give Personal Data to us directly (such as on our “Contact Us” page), requesting information, including a product demo, registering for a webinar or other event, or subscribing to emailing lists. While the type of data we collect depends on the nature of the inquiry, this typically includes name and contact details, company information, and phone number. We also automatically collect certain information relating to your use of our Site, described under the Automatically Collected Data section below.
Testimonials: We collect and display personal testimonials of satisfied Customers and users on the Services in addition to other endorsements. With your consent, we may post your testimonial along with your name, on the Services. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Service Data: We collect Personal Data about our Customers’ contacts, such as general directory information from alumni databases, graduation year and historical giving data. We collect this information directly from our Customers under the direction of our Customers and have no relationship with those contacts.
We also enable our Customers to connect their data with insights (including posts, career information) from various publicly available sources, including the United States Census, LinkedIn, Facebook, Zillow, giving Customers the ability to engage alumni in meaningful conversations based on that person’s interests and preferences.
Alumni Data Used in EverTrue Alumni Community: Profile information for Customers’ contacts and users of the Services will be publicly accessible and viewable in our EverTrue Alumni Community directory. If you are a contact of one of our Customers and would like to request removal of an unauthorized profile, or deletion or deactivation of a profile, please contact our Customer directly.
As an EverTrue Alumni Community user, you may submit corrections or updates regarding other Community users.
A Customer or other registered user may request the removal, deletion or deactivation of a profile such customer has created by contacting EverTrue at email@example.com. Some profile information may remain on publicly viewable areas of the Services if it is publicly available information or another user has provided it in connection with such use of the Services, and that profile information may remain on our servers or in our records after it is no longer viewable by other users of the Services.
EverTrue has no direct relationship with the individuals whose Personal Data we process on behalf of Customers. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to EverTrue’s customer (the data controller). If requested to remove data by our Customers we will respond within a reasonable timeframe or as required by applicable law.
Automatically Collected Data: When you use the Services or the App, the following information is created and automatically logged in our systems:
- Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site, or that the App automatically send when you use them. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Services.
- Device information: Includes type of device, including mobile device, you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.
- Usage Information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, the other users you interact with and the time, frequency and duration of your activities.
- Geo-Location Data: We collect your location-based information for the purpose of assisting you in locating places of interest and identifying contacts or other users of the Services who live or work in your geographic area. For example, a EverTrue Platform user may view prospective donors and a EverTrue Alumni Community user may locate fellow alumni users of the Services in a given city or neighborhood. We will share your location-based information with our mapping provider for the sole purpose of providing you with this service. You may opt-out of location based services at any time by editing the setting at the device level or by emailing us at firstname.lastname@example.org.
We do not link this automatically collected data to other information we collect about you.
2. HOW WE USE INFORMATION
We use the data we collect, described above, as follows:
To provide the Services, process transactions and respond to your requests. This is necessary to perform our contract with you.
As necessary for certain legitimate business interests, including:
- To send administrative information to you, for example, information regarding the Site and changes to our terms, conditions, and policies.
- To better understand how visitors interact with the Services in order to personalize your experience with EverTrue (to this end, we use data relating to your use of and interaction with the Site and the Services, including use of product features by you and information that we obtain through cookies).
- To conduct analytics to inform our marketing strategy and enable us to enhance and personalize our communications and the experience and Services we offer to Customers and App Users.
- To conduct research on our user demographics, interests and behavior based on the Personal Data and other information provided to us, in an ongoing effort to better understand and serve the users of or visitors to the Services. This research may be compiled and analyzed on an aggregate basis, and EverTrue may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally.
- To prevent fraud or criminal activity, misuses of our products or services, and ensure the security of our IT systems, architecture and networks.
- To (a) comply with legal obligations and legal process, (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our terms and conditions; (d) protect our operations; (e) protect our rights, privacy, safety or property, and/or that of you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain.
- If you ask us to delete your data and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
Marketing. To send you updates and information about our new products and services, upcoming events or other promotions or news by email or push notification. Where required by law we will only send you marketing information if you consent to us doing so at the time you provide us your Personal Data. You may opt-out of receiving such emails by following the instructions in each promotional email we send you or by updating your user settings. In addition, if at any time you wish not to receive future communications or you wish to have your name deleted from our mailing lists, please contact us at email@example.com. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.
Behavioral Targeting. We partner with third parties to display advertising in connection with the Services and manage our advertising on other sites. Our third-party partners may use technologies such as cookies to gather information about your activities on the Services and other sites in order to provide you with advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may contact use at firstname.lastname@example.org. Please note this does not opt you out of being served ads. You will continue to receive generic ads. Please read the “Cookie” section below for additional information on our practices in relation to cookies used on the Site.
For information on your rights under applicable European Union (EU) law, please see the “EU Users” section below.
3. SHARING AND DISCLOSURE
We may share your Personal Data with certain third parties without further notice to you in the following circumstances:
- Third-Party Services. We may share Personal Data such as your name and email address with and derive additional information from third-party services to facilitate the delivery of the Services. For example, we use LinkedIn to determine employment and professional information, Facebook to determine an individual’s affinity towards an EverTrue customer and a mapping service provider to display your current location or locations you may visit.
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. You will be notified via email and/or a prominent notice on the Services of any change in ownership or any material changes in uses of Personal Data, as well as any choices you may have regarding your Personal Data.
- Legal Requirements: If required to do so by law, applicable regulation or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of EverTrue, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the App, or the public, or (iv) protect EverTrue against legal liability.
Our policy is to keep your Personal Data only for as long as is reasonably necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
We will retain Service Data for as long as needed to perform under the each specific contract with Customers.
5. YOUR CHOICES
You can use the Services without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.
6. ACCESS/UPDATE YOUR INFORMATION
If you would like to update your Personal Data, or wish to have it deleted from our systems, or wish to deactivate your account, you may correct, update, amend, delete (or ask to have deleted any such information from a public forum, directory or testimonial on our Services, or from your individual user account), by making the change through your account or by contacting us at email@example.com. We will address your request as required by applicable law.
7. EU USERS
Scope. This section applies if you are located in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway).
Data Controller. EverTrue is the data controller for Personal Data about our Customers, App Users and Site Visitors. We act as a data processor (or service provider) for the processing of Service Data on behalf of our Customers. To find out our contact details, please see the “Contact Us” section below, which also provides the contact details of our representative in the EU (DPR Group) for purposes of the EU General Data Protection Regulation.
Your Rights. Subject to EU law, you have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that we processed with automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest (described under the “How We Use Data” section above) to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
- If we are processing your Personal Data for direct marketing.
- 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.
- Right to make a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
You may contact us at firstname.lastname@example.org to exercise your rights.
8. YOUR CALIFORNIA PRIVACY RIGHTS
California law permits visitors who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To request such information, please contact us at email@example.com. Within thirty (30) days of receiving such a request, we will provide a list of the categories of Personal Data disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email address specified in this paragraph.
EverTrue does not knowingly collect Personal Data from children under the age of 13. If you believe that a child under the age of 13 has provided Personal Data to EverTrue through the Services or mobile app please contact us at firstname.lastname@example.org and we will endeavor to delete that information from our databases. If you are under the age of 13, please do not submit any Personal Data through the Services.
10. SOCIAL MEDIA
11. LINKS TO OTHER WEBSITES
If you choose to forward a position or job opening on our careers page, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him to apply for the job position. EverTrue stores this information for the sole purpose of sending this one-time email.
Your friend may contact us at email@example.com to request that we remove this information from our database.
14. PUBLICLY POSTED INFORMATION
We take reasonable administrative and technical steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure. Therefore, while we strive to protect your data, we cannot guarantee its absolute security. Please keep this in mind when disclosing Personal Data to EverTrue or over the Internet.
In operating this Site, we use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site.
- Strictly Necessary Cookies: Used to provide the Services available through our Site and to use some of their features, such as the ability to log-in and access to secure areas. These cookies are served by EverTrue and are essential for using and navigating the Site. Without these cookies, basic functions of our Site would not work. Because these cookies are strictly necessary to deliver the Site and the Services, you cannot refuse them.
- Analytics: Used to better understand the behavior of the users on our Services and improve our Services accordingly, for example by making sure users are finding what they need easily.
- Google Analytics – A web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your IP address) will be transmitted to and stored by Google on servers in the United States (Google is certified to the Privacy Shield for data transfers). How long a Google Analytics cookie remains on your computer or device depends on what it is and what it is used for. Some Google Analytics cookies expire at the end of your browser session, whilst others can remain for up to two years. You can prevent your data from being collected by Google Analytics on our Site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser. For more information on Google Analytics privacy practices, read here.
- HubSpot – Helps us analyze and evaluate the use of our Site and improve our services and features (read more details on the type of cookies here). You can learn more about HubSpot’s privacy practices here.
- Mixpanel – Provides us aggregated data around usage and web traffic. You can opt out of Mixpanel tracking by visiting: https://mixpanel.com/optout/.
- Stripe – Used to track cart abandonment. Learn more about Stripe’s about privacy practices here.
- HelpScout – Used for customer service support. Learn more about Stripe’s about privacy practices here.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.
To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org and/or or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org, and follow the opt-out instructions there or if located in the European Union, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool here. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
18. CONTACT US
330 Congress Street, 2nd Floor
Boston, MA 02210
If you are an individual in the EU, you can also contact Data Protection Representative Limited (trading as “DPR Group”), a company registered in the Republic of Ireland (registered number 616588, whose registered address is at Office 29, Clifton House Business Centre, Fitzwilliam Street Lower, Dublin 2, D02XT91), who has been appointed as Evertrue’s representative in the EU pursuant to Article 27 of the General Data Protection Regulation on matters related to the processing of your personal data. You can contact DPR Group at “evertrue @ dpr dot EU dot COM” or submit a data inquiry/subject access request here. Please note this email address is solely for the purposes of raising subject access requests and other queries in respect of the personal data held by the company in respect of EU-based persons. Please direct all other inquiries to firstname.lastname@example.org.