Privacy Policy

We at True Pedigree, LLC and True Pedigree Consulting LLC (collectively “True Pedigree” or “we” or “us”) take your privacy seriously. This Privacy Policy describes the personal information we collect, how we use it, and the circumstances where we may share it. We help our business customers operating charities (our “Customers”) operate their charities by providing a platform for our Customers to collect and process donor information. By using our website (http://www.TruePedigree.com) or by using our platform or any of our products or services (the “Services”), you acknowledge that you understand the practices and policies outlined below.

1. Personal Information We Collect

Customer Information.

In order to serve our Customers, we collect the following categories and types of personal information:

Employee information including your name, company email, company name, company website URL.
Correspondence, which may include any personal information provided during an email correspondence or customer service engagement.
Billing, payment and administrative finance information.
Information about how our Customers use our Services, including our website which may include engagement activities with our website, platform, or other Services, and communications. We may also use tools to measure your website and platform visits, such as time spent on our website and platform, the pages you may have clicked on, behavioral activity, and metadata associated with software interactions, for which we may use pixel tags and cookies.
We may send email updates and collect information about your interaction with our emails, such as whether you opened or clicked on an email we sent you.

Donor Information.

Our Customers upload information to our Services regarding their donors (“Donors”). This information may include:

Contact information such as name, email address, phone number, postal address.
Family or legal beneficiary information such names, email addresses, phone numbers or postal addresses and their familial or legal association with any Donors.
Billing and financial information necessary to process donations, which may include historical and current banking or investment information.

2. How We Use Personal Information

We collect, use, process, and store personal information in order to:

Provide our Customers with the Services, including providing our platform for Customers to input Donor information and to process payment information.
Process transactions from our Customers.
Build and improve the Services.
Provide customer service.
Communicate with you, including making you aware of product and feature promotions.
Personalize our Services.
To authenticate, verify or otherwise ensure compliance with Customer written instructions or to mitigate the risk of fraud.
Receive and process job applications for careers with us.
Detect, investigate, and prevent fraudulent or illegal activity associated with True Pedigree’s property or those of our customers.
Comply with applicable law, legal process or regulations.

3. How We Disclose Personal Information

Subject to Customer agreements, we may disclose personal information under the following circumstances:

To facilitate the Services based on written instructions from our Customers.
With service providers that contractually agree to safeguard the information, such as cloud hosting, customer information management, customer communications and website analytics.
With any of our affiliated companies, including Sideman & Bancroft LLP, as well as any subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy).
To protect the legal rights of our company, our employees, our agents, and our affiliates.
If we believe that disclosure is necessary to comply with the law or valid legal process.
To protect the security or integrity of the Services or safety of True Pedigree and our employees.
To detect and protect against fraud.
In the event True Pedigree is acquired, merges with another company or sells any business assets (including during any due diligence process).
Anytime with your consent.

This means that the information we share does not identify specific individuals, or is combined with other data to protect your privacy.

4. Your Privacy Choices

If you are a True Pedigree customer, you may contact us at any time and request the following choices with our use of your personal information:

Access. We can provide you with the personal information that we maintain about you.
Correct. We will correct any mistakes with your personal information.
Deletion. You can request that we delete any personal information about you, unless we are required by contract or law to retain it.
Opt-Out. You may request that we cease using your information for marketing or other purposes that are not required to provide the Services you’ve requested, notably:
- Marketing Emails. To opt out of marketing e-mail communications, you may click the ‘unsubscribe’ link in the marketing emails.

If you are an employee of one of our Customers, are a Donor, or otherwise believe True Pedigree is processing your personal information on behalf of a Customer or Donor, please direct any privacy requests to the Customer or Donor with whom you believe shared your personal information with True Pedigree.

5. Security & Retention

We use industry standard technical, administrative, and physical controls to protect your personal information. While we endeavor to protect the privacy of your personal information, we cannot guarantee complete security.

We will retain Customer and Donor personal information according to the terms of our written agreements.

6. U.S. State-Specific Notice

Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CPRA” (collectively, the “CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”) the Utah Consumer Privacy Act (“UCPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), and the Montana Consumer Data Privacy Act (“MTCDPA”) create additional privacy obligations for businesses. This section 6 applies to the extent our Customers are subject to these laws.

Sensitive Information.

Our Customers may upload select pieces of personal information to our Services that may be defined as ‘sensitive personal information’ under various state privacy laws, including Donors’ banking or investment information, government issued IDs, and social security numbers.

While we may process sensitive personal information on behalf of our Customers, the Services are limited to administrative and contact management under specific written instructions by our Customers, which is not defined as a ‘commercial purpose’ under these state privacy laws.

We do not ‘sell’ or ‘share’ any personal or sensitive personal information processed through our Services.

Service Provider/Processor Designation.

To the extent these laws are applicable, True Pedigree operates as a ‘Processor’ (and a ‘Service Provider’ under the CCPA) to its Customers.

7. Children’s Privacy

True Pedigree does not intend for our Services to be used by anyone under the age of 18 (“Minors”). If you are under 18 years of age, please do not send any personal information about yourself to us. If you believe we have directly obtained personal information associated with children under the age of 18, please contact us at privacy@truepedigree.com and we will delete it. If you believe True Pedigree is processing personal information of a Minor that was uploaded by a Customer utilizing our Services, please contact the Donor or Customer in order to request removal of any such information from our systems.

8. Third-Party Links

The Services may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our sites and to read the privacy statements of any other site that collects personally identifiable information.

9. Changes to this policy

If we change this policy, we will post an update on our home page. If the change involves something substantially different from our current policy, we will post the update in advance of the change taking place or send an email to everyone subscribed to our email updates.

10. Contact Us

If you have any questions about our privacy practices, or if you wish to make a request, please contact us at either:

privacy@truepedigree.com

or

True Pedigree, Inc.

Attn: Privacy

One Embarcadero Center

Twenty-Second Floor

San Francisco, CA 94111