Privacy Policy

Effective Date: October 31, 2015

Last Updated: June 7, 2023

The Privacy Policy describes how Girls Who Invest, Inc. (“GWI,” ”us,” “we,” and “our”), collects, stores, uses and discloses personal information about you.  This Privacy Policy applies to information we collect or receive when you visit or use our website (“Site”), engage with us on social media, communicate with us, donate to us, participate in one of our programs (our “Programs"), or otherwise interact with us.

If you have any questions, please contact us as provided below. You may download a copy of this Privacy Policy by clicking here.  If you have a disability and need to receive this Privacy Policy in a different format, please contact us at info@girlswhoinvest.org

Please read this Privacy Policy carefully to understand our policies and practices. By using the Site or providing your personal information to us, you signify that you consent to the use of your information in accordance with this Privacy Policy. If you do not agree with any term in this Privacy Policy, you should not access and use Site and please do not otherwise provide us with any personal information.

 

Categories of Personal Information We Collect

The type of information that we collect depends on your interaction and relationship with us.  We collect the below categories and types of personal information with your consent or as otherwise required or permitted by law.

  • Contact Information.  We collect full name, email address, and telephone number, and business contact information. 
  • Identifiers.  We collect internet protocol address, social media handles or IDs (such as your LinkedIn username) and account usernames and passwords. 
  • Financial Information.  We collect financial or bank account information, payment card number, payment card expiration date and CVV code, and billing address. 
  • Commercial Information. We collect information about Programs that you may consider or be involved in and records and transcripts of communications with us, such as communications with our customer service team.
  • Internet or Electronic Usage Data.  We collect data related to network and website interaction history, IP address, website cookie information, interaction with advertisements and browsing time.
  • Geolocation Data.  We collect geolocation data including the general region or area from which you access our Site. 
  • Inferences:  We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.

Sources Of Personal Information

We collect personal information in the following ways:

  • Directly from you.  We collect contact information, identifiers, professional or employment information, financial information and commercial information that you provide directly to us.
  • Automatically.  When you access our Site, we collect identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies. 
  • From third parties.  We may collect contact information, identifiers, commercial information, professional or employment information, and inferences from third-parties including our vendors, clients, or service providers.
  • Social media platforms.  Depending on the information you choose to share and your privacy settings, we may collect contact information, identifiers, or traits, geolocation data, commercial information, professional or employment information, internet or electronic usage data, and inferences. Based on the way you have set your privacy settings on your social media accounts, most social media platforms, like Facebook and Instagram, analyze data about how you interact with our Site and combine it with information on other users to provide us information about you.  In addition, we may receive information about you if other users interact with us on social media and information about you is visible to us, for example the fact that you are “friends” or other public-facing profile information.

Purposes for Collecting Personal Information

We use personal information for the following business and commercial purposes:

  • Providing our Programs.  We use contact information, identifiers, financial information, commercial information, professional and employment information to provide and administer our Programs and provide updates requested by participants or applicants.
  • Transactional Purposes.  We use contact information, identifiers, financial information, professional or employment information, and commercial information to: (i) communicate with you, including when you use the chat feature on our Site; (ii) provide you with customer assistance; (iii) administer contracts with our vendors, customers, and service providers; (iv) provide supporting business activities such as billing and collections, procurement, and tax related activities; (v) and process payments and donations.
  • Business Operations.  We use contact information, identifiers, financial information, professional or employment information, and inferences for our day-to-day business operations including maintaining records, manage our facilities, planning, budgeting, calibration, database administration, surveys, evaluations, reports, compliance, regulatory, audit, investigative and disciplinary purposes and other ethics and compliance reporting tools, and to support our business operations.
  • Analytics.  We use identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.
  • Marketing and Promotional Purposes.  We use contact information, identifiers, financial information, professional or employment information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, prospect for new donors or partners, engage in donor or partner relationship management, donor engagement, administering contests, sweepstakes and other promotions, and to provide you with information about us, including blog posts, newsletters and personalized marketing communications. 
  • Maintenance and Improvement of our Site and Systems.  We use contact information, identifiers, geolocation data, internet or electronic usage data to improve our Site and systems, provide and maintain functionality on our Site and systems, including the live chat or feature on our Site, and help us diagnose technical and service problems and administer our Site and systems.  Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT support.
  • Develop and Improve Our Services.  We use contact information, identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, inferences, and professional or employment information to help us develop new products and services and to improve and analyze our existing service offerings.
  • Security and Fraud Prevention. We use  contact information, identifiers, financial information, commercial information, internet or electronic usage data, geolocation data, professional or employment information, and inferences to: (i) protect us, our employees, and our Site, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct; (ii) enforce our policies and terms; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
  • Legal: We use contact information, identifiers, financial information, commercial information, internet or electronic usage data, geolocation data, professional or employment information, and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
  • Other Purposes:  We may use contact information, identifiers, financial information, commercial information, internet or electronic usage data, geolocation data, professional or employment information, and inferences for other reasons we may describe to you.

How We Disclose Personal Information

We disclose personal information in the following circumstances:

  • Service Providers.  We may share personal information with vendors and service providers who support the operation of our Services, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting, payment processing, email delivery, marketing, insurance, operating systems and platforms, transportation, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf. 
  • Donations.  We use a third party service provider to assist us in processing payment information related to any donations you make through our Sitee.  When you use the “Donate” function on our Site, you will be directed to our third party service provider’s website to complete the transaction.  Our third party service provider may in turn use a third party payment processor to facilitate those donation transactions. our use of our third party service provider’s website to make a donation is governed by the terms of use and privacy policy of our third party service provider.  We encourage you to read their privacy policy before submitting your payment and other personal information to them.
  • Program Partners.  We may share personal information with third party investment firms that provide internships to participants in our Programs.
  • Analytics/Advertising Partners.  We may share personal information with third party analytics or advertising partners, including social media platforms and networks, who provide analytics or marketing and advertising services to us. 
  • Professional Advisors.  We may share information with professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us. 
  • Government Entities.  We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation.  This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
  • Corporate Transaction Recipients.  We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.  
  • Other Reasons.  We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

We Combine Information

We combine information we obtain from different sources with publicly available information, including to create inferences about you.  For example, we may combine information that we have collected offline with information we collect online.  We combine information that we have collected across other third party sites.  We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

How Long We Keep Personal Information

We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests).  We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future.  We use the following criteria to determine retention periods:

  • how long the information is needed to provide our services, operate our business and assert our legal rights;
  • whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
  • whether any law, statute, or regulation allows for a specific retention period;
  • whether an individual has agreed to a longer retention period;
  • whether the data is considered to be sensitive data; and
  • what the expectation for retention was at the time the data was provided to us.

Cookies, Analytics, and Other Tracking Technology

Cookies and Tracking Technology

We want you to be aware that certain online tools exist to help us serve and recognize you when you visit our Site. We receive and store certain types of information when you visit our Site. When you access the website, we (including third-party analytics and advertising companies we work with) may place small data files on your computer or other device.  These data files may be web beacons, cookies, clear gifs, pixel tags, e-tags, flash cookies, log files, or other local storage provided by your browser or associated applications.  These tracking technologies, which are often referred to collectively as cookies, collect information about your use of the Site and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked and conversion information.  We use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity.  If you want to remove or block cookies, you may be able to update your browser settings. You can also find instructions on how to manage cookies on different types of web browsers at www.allaboutcookies.org.  

Do Not Track Signals

Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity.  These features are not yet uniform across browsers.  Our Site is thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Google Analytics

We use analytics services provided by Google Analytics.  If you would like more information on how Google uses data when you visit or use our Site, please visit www.google.com/policies/privacy/partners.  If you would like to opt-out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.

Browsing Session Information

We use technology that maintains a record of your browsing session.  We use this information for quality control, customer service, fraud prevention and security, and marketing purposes.

Links to Other Websites

Our Site may include links to other websites or applications whose privacy practices may differ from ours.  If you submit personal information to any of those websites or applications, your information is governed by their privacy policies.  We encourage you to carefully read the privacy policy of any website you visit or application that you use.

Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

This Site is Not Intended for Children Under 13

Although Girls Inc. is a non-profit organization and does not operate a commercial website, we pay special attention to protecting the privacy of visitors under age 13. We do not knowingly collect or store any personal information from anyone under the age of 13.  If we become aware that we have collected or stored personal information from an individual under age 13, we will remove his or her personal information from our files.  If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us by sending an email to info@girlswhoinvest.org.

Marketing Communications

Marketing Emails.  You can opt out of marketing or advertising emails by using the "unsubscribe" link or mechanism noted in communications you receive from us.  You may also request to opt out of marketing or advertising emails by contacting us at info@girlswhoinvest.org.  Once we process your request, we will cease using the information for such purposes at no charge to you.  If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.

Phone Calls and Text Messages.  If you do not want to receive marketing phone calls or text messages from us, please inform us that you no longer want to receive calls from us when you receive a call from us, or reply STOP to a text message from us.  You can also opt-out of telemarketing by contacting us at info@girlswhoinvest.org.

Processing in the United States

Please be aware that information we obtain about you may be processed in the United States by our service providers or us. By using the Site or Services or otherwise providing you with personal information, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own, as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may not afford the same level of protection as the laws in your own jurisdiction.

Updates to Our Privacy Policy

From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law.  We will also post an updated copy on the website where this appears. Please check our website periodically for updates.  The “Last Updated” legend above indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy.

Contact Us

If you have any questions about this Policy or our privacy practices, please email us at info@girlswhoinvest.org or write to us at:

Girls Who Invest, Inc.
1345 Avenue of the Americas
33rd Floor
New York, New York 10105