Privacy Policy

What Personal Information do we collect?

You can visit and enjoy our Site and Application without disclosing any Personal Information about yourself. However, for the services to work properly you will need you to disclose certain Personal Information about yourself to us.

For the purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual, device, or household. 

1. User Provided Information
   
   
   1. Organization and investment information. We may collect and make the name, website, geographic location, and description of your organization, the amount and purpose of your investment, investment impact objectives, the sectors and geographic location of interest to you and any other information you provide about your organization and investments available to and searchable by the public on the Site and Application, and this information may be downloaded or exported by the public from the Site and Application.
      
      
   2. User messages and content. The Site and Application may contain message boards, chat rooms, forums, bulletin boards, and other interactive features that allow you to post, submit, publish, display or transmit other users' content or materials on or through the Site and Application. Such information may be available to and searchable by the public on the Site and Application.
      
      
   3. Account and membership information. You may be asked to create a username and password, along with providing other registration information (collectively "Registration Data") as part of the registration process. You are responsible for the accuracy and currency of your Registration Data. 
      
      If you register for a member account with the Site or Application or for inclusion in a member profile or membership directory, you may be asked to provide us with Personal Information, such as the name and email address of a primary contact person. If you provide the Site or Application with that Personal Information, such Personal Information will be available and searchable as part of a member profile for inclusion in a membership directory accessible only by other paying members registered with the Site or Application.

   4. Feedback and survey information. We may ask you for feedback about the GIIN or a project hosted or managed by the GIIN or to complete surveys.

   5. Research project. If you participate in a research project with us, we may record our interviews with your consent and in accordance with our Terms of Contribution which will be provided to you.

   6. Event and subscription information. If you register for events, newsletters, or publications on the Site or Application or otherwise, we may ask you for Personal Information, including your name (first and last name) and other contact details.

   7. Account security and verification. You may be asked to provide your mobile number to receive SMS messages for account security and verification purposes. 

   8. Other information. You may be asked to provide us with other Personal Information, such as your address or the address of a contact person, and your credit card information.

      We use trusted third-party services to process all payment and credit card transactions. While our site may prompt you for credit card information during checkout, we do not store or collect this data ourselves.

2. Records of Correspondence.

   The GIIN may collect records and copies of your correspondence with us (including email addresses) if you contact us. 

3. Third Parties
   
   We may also collect personal information indirectly (i.e. contact details such as name, position, organization) through partners for the purpose of promoting our events and programs.

4. Cookies and other trackers.
   
   Subject to your consent where required, when you visit the Site or Application, we may use cookies and other tracking technologies as further described below. 
   
   Cookies
   
   “Cookies” are small data files sent to your computer to uniquely identify your browser or let the GIIN help you log in faster and enhance your navigation through the Site or Application. A persistent cookie remains on your computer after you close your browser so that it can be used by your browser on subsequent visits to the Site or Application. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser.
   If you consented to our use of cookies but later wish to opt out, you may change, at any time, your browser settings in order to block the cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. In this respect, the following links provide instructions in order to manage your cookies preferences:

   • Chrome: https://support.google.com/chrome/answer/95647?hl=en

   • Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac

   • Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09 

   • Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=Enabling+and+disabling+cookies

   • Finally, you may visit www.aboutcookies.org, a website providing comprehensive information about how to manage your cookies settings on a broad variety of browsers.
     However, some features of the Site or Application may not function properly if the ability to accept cookies is disabled.
     We will retain cookies for thirteen (13) months from the collection of your consent.

   Log files
   
   Log file information is automatically reported by your browser each time you access a web page. When you use the Site or Application, our servers may automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
   
   Clear GIFs Information.
   
   When you use the Site or Application, we may employ clear GIFs (also known as web beacons) which are used to track the online usage patterns of our users anonymously. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information is used to enable more accurate reporting and make the Site better for our users.

How do we use Personal Information?

We use information that we collect about you or that you provide to us, including any Personal Information, in the following ways:

1. We process your Personal Information to carry out our obligations and enforce our rights arising from the contract entered into between you and us, in particular to:
   
   
   • Provide you with information, products or services that you request from us;
   • Manage your user account;
   • Process your application for membership;
   • Carry out our obligations arising from any contracts entered into between you and us (which involve notably the creation of your member profile for inclusion in our member directory, processing your payment information for billing purposes, financial account management, contract management and corporate governance), otherwise the contract may not be executed.
     
     
2. We also process your Personal Information to enable us to achieve our legitimate objectives, specifically:
   
   
   • improving our Site, Application, services and products we provide to you, and offering you a better experience on our Site and Application;
   • to conduct user analytics;
   • to carry out IT, Application and Site administration;
   • to conduct research and development, including through surveys and feedback, and processing for statistical purposes;
   • to complete a potential merger, acquisition or liquidation;
   • to answer your request for support or inquiry;
   •  to process your application to a position at the GIIN;
   •  to comply with laws and regulations (including record-keeping and “know-your-customer” requirements, anti-money laundering, anti-bribery and professional regulations), and respond to requests from, and other communications with, competent public, governmental, judicial or other regulatory authorities; 
   • to protect your, our, and others’ rights, property, and safety, which includes fraud prevention and security measures on our Site and Application;
   •  to confirm your identity;
   • to enforce any agreement with you; and
   • to resolve disputes.
     
     
3. Subject to your prior consent, where required, we may also process your Personal Information to:
   
   
   • send you newsletters, and information regarding educational and networking opportunities;
   • conduct research. If you agree to contribute data, for example when taking part in supplementary research, we will use your Personal Information for the purpose of that research project or program (full details of how your Personal Information will be used will be given to you at the time you agree to participate via our Terms of Contribution);
   • keep your information to give you the opportunity to apply for future positions at the GIIN.
     
     You may withdraw your consent at any time by contacting us at [email protected].
     
     
4. We process your Personal Information as needed to enable us to fulfill the legal and regulatory obligations to which the GIIN is subject under applicable law, regulation, court order or other legal processes, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities or record-keeping requirements. For example, we may process your Personal Information under “know your customer”, anti-money laundering regulations, anti-bribery regulations and professional regulations. 

How do we disclose Personal Information?

1. We use information that we collect about you or that you provide to us, including any Personal Information, in the following ways:
   
   
   1. For the purposes referred to under this Privacy Policy, the GIIN may need to disclose certain Personal Information to recipients acting on behalf of the GIIN as processors. In this respect, the processors to whom we disclose your Personal Information are contractors and third-party service providers, with the relevant contractual provisions in place to ensure the security of your Personal Information and compliance with applicable laws and regulations. Such third-party providers may include AI providers and other IT services providers to help us manage our customer relationship or handle the billing and operate the GIIN’s systems. 
      
      
   2. We may disclose Personal Information we collect from you to third parties acting as controllers to the extent necessary: (A) to comply with the law or in response to a subpoena, court order, government request, or other legal process; (B) to protect the interests, rights, safety, or property of the GIIN or others (including to address fraud, illegal activity, claims and other liabilities, and security or technical issues); (C) to enforce any terms of service on the Site and Application; (D) in connection with a merger, acquisition, or liquidation of the GIIN.
      
      
   3. We may share or disclose your Personal Information with your consent, such as if you choose to sign on to the Site and Application through a third-party service.
      
      
   4. As mentioned above, we may make certain information you provide about your organization and investments available to and searchable by the public on the Site and Application, and this information may be downloaded or exported by the public from the Site and Application.
      
      
   5. We may disclose anonymous demographic information to third parties, but this information cannot be linked to any Personal Information that can identify you.
      
      
   6. We may disclose mobile information and related messaging data to messaging service providers solely to deliver non‑marketing SMS text messages for account security and verification. We do not share mobile information with third parties or affiliates for marketing or promotional purposes without your consent. SMS-related opt‑in data and consent are excluded from other sharing categories and are not shared with any third parties.
      
      
   7. We will not sell, lease, or share your Personal Information with or to anyone else, except as provided in this Privacy Policy.
      
      
2. To balance our interests and yours, we have taken steps to ensure that any third parties maintain appropriate technical and organizational measures to keep your personal information secure.
   
   
3. If we are involved in strategic transactions including any sale, merger, acquisition, joint venture, assignment, transfer, re-organization, bankruptcy, or receivership, we may disclose Personal Information to actual or prospective counterparties and their representatives, and this information may be transferred to a successor or affiliate as part of that transaction along with other assets. 

Transfer of Personal Information

1. As the GIIN is located in the United States, your Personal Information needs to be transferred to the United States for the purposes referred to under this Privacy Policy,
   
   
2. In addition, when we disclose your Personal Information to third parties mentioned above in the “How do we disclose your Personal Information” section, it may require transfers of your Personal Information overseas. This may include transfers to countries outside of the country of collection (including, without limitation, outside of the European Economic Area or the UK) whose laws provide levels of protection for Personal Information that are not always equivalent to the level of protection that may be provided in your own country.
   
   
3. Where your Personal Information is transferred outside the country of collection, the GIIN implements appropriate safeguards in accordance with applicable data protection laws. As applicable, such appropriate safeguards may include adopting standard contractual clauses issued by the European Commission. Please contact [email protected] should you need more details on the applicable safeguards and transfers.

Retention of Personal Information

The GIIN shall retain your Personal Information for no longer than is necessary for the purposes identified under this Privacy Policy.

The GIIN will keep your Personal Information for the duration of our contractual relationship extended by five (5) years. If you have created an account/member profile on the Site or Application, please note that the GIIN will delete your Personal Information after two (2) years of inactivity on your account/member profile.

If we do not have any contractual relationship, the GIIN will keep your Personal Information for three (3) years after your last correspondence with us.

For the applicants who are hired, the GIIN will keep your Personal Information in accordance with the employee notice applicable to you. If you do not receive a job offer from the GIIN, we will delete your Personal Information upon completion of the recruitment process. A longer retention period may apply if required by applicable law (for example, for accounting or statutory purposes) or upon your request. 

With respect to the processing carried out in order to protect your, our, and others’ rights, property, and safety, the GIIN will keep your Personal Information for the time of the relevant dispute or statute limitation period.

As to the processing carried out in order to comply with a legal obligation, the GIIN will keep your Personal Information for the duration of such legal obligation.

On the expiry of the applicable data retention period, the GIIN undertakes to erase or irrevocably anonymize the relevant Personal Information.

Privacy Rights

You can review, update, or remove the Personal Information you included in your member profile by logging into the Site and Application, visiting your member profile page, and making changes. You also have various rights in relation to the processing of your Personal Information, depending on your jurisdiction and the relevant situation. These rights may include:

• Right of Access: the right to request confirmation as to whether or not your Personal Information is being processed by the GIIN and, if so, the right to receive a copy of it;
• Right to Rectification: the right to request the rectification of your Personal Information if you find that it is inaccurate and the right to have incomplete Personal Information completed;
• Right to Erasure: the right to request the erasure or deletion of your Personal Information depending on the circumstances. For example, this right does not apply if the processing is necessary to establish, exercise, or defend legal claims;
• Right to Restriction: the right to request the restriction of processing of your Personal Information, depending on the circumstances;
• Right to Data Portability: the right to request a copy of your Personal Information provided to us, in a structured, commonly used, and machine-readable format; and
• Right to Object: the right to object, on grounds relating to your particular situation, to the processing of your Personal Information. For example, you can object at any time to the processing of your Personal Information for direct marketing communications.

To exercise any of your rights, please contact us by email to the address [email protected]. 

In any case, you also have the right to lodge a complaint with the competent data protection authority.

Protection of Personal Information

In order to protect your Personal Information, the GIIN has put in place what the GIIN believes to be appropriate physical, electronic, and managerial procedures to safeguard and secure your Personal Information

Children's Privacy

The GIIN does not knowingly collect or solicit Personal Information from anyone under the age of sixteen (16) or knowingly allow such persons to register with the Site. If we become aware that we have collected Personal Information from a child under the age of sixteen (16) without verified parental consent, we will delete that Personal Information from the Site and Application.

Links

Our Site and Application contain links to other websites and/or products operated by unrelated third parties. In addition, if you click on an advertisement on our Site or Application, you may be directed to a web page within our Site or Application or to a third-party website or product. Please note that we are not responsible for the privacy practices of third-party websites or products. We encourage you to be aware of this when your leave our Site or Application and to read the privacy policies of every website and product that collects personally identifiable information from you. This Privacy Policy applies only to this Site and Application, unless you are notified otherwise upon accessing any third-party website or product, in which case the terms and conditions set forth in such notification will apply.

Changes to this Privacy Policy

The GIIN reserves the right to change this Privacy Policy at any time at its sole discretion by posting revisions on the Site. Such revisions will be effective immediately upon posting them to the Site, and we will notify you in this respect when those changes are material or as required by law. If such revisions result in changes to the processing of your Personal Information that may require your consent, you will have a choice to consent as to whether we can process your personal information in this different manner.

If you have any questions or concerns about our practices or this Privacy Policy, please contact [email protected], or send mail to:

Global Impact Investing Network
Attn: Privacy
One Battery Park Plaza, Suite 202
New York, NY 10004