CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on December 20, 2021 and historic versions can be obtained by contacting us. This version replaces all previous versions with effect from the effective date of this privacy policy; namely December 20, 2021. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us

INFORMATION WE COLLECT

As further described below, when you use or otherwise access the Services, we collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from your browser.

Information That You Provide Directly to Us:

1. 1. Creation of a fundraising cause:

   We, Legash Pay, have the only right to add causes on the platform. It’s not eligible for “end-users” without Legash Pay approval.

   Our payment processors collect and maintain information related to your withdrawal of funds from any cause

2. 2.Donation information:

   n the Legash Pay Platform, when you donate to a fundraising cause, we collect your contact details (such as name and email address), zip code, country, and any information you choose to provide us (such as a description of why you have donated).

   Legash Pay’s partner payment processor, Cyber Source, collect your credit card details and other information necessary to process the donation

3. 3.Communications:

   You can post comments, leave feedback, send thank-you notes or otherwise communicate with other users through our Platform. Any content, including such comments, feedback, and notes are you choose to post through our Platform are available to the public by default. You may also contact us via a contact form, email, or by other means (for example, with questions about our Services, for customer support, or to let us know your ideas for new products or modifications to existing products). When you do so, we collect the information you choose to provide us, such as your contact details, any images you choose to upload and the contents and nature of your message.

   Please remember that any information that is disclosed in these areas becomes public information for both us and other users to use and share. Please be considerate and respectful of others while using the community to share your opinions. We reserve the right, but do not have the obligation, to review and monitor such posting or any other content on our Services, and to remove postings or content that may be viewed as inappropriate or offensive to others.

4. 4.Information relating to third parties:

   If you use any feature of the Services that allows you to communicate with third parties (such as to refer a third party to the Services or to communicate with them regarding a cause or a donation), either by submitting Third-Party Data to the Services or otherwise permitting the Services to automatically access Third-Party Data in your possession, you acknowledge and agree that you have the authority of the relevant third party for us to access and use the relevant Third-Party Data and that you have notified these third parties and informed them how their information is collected and used by Legash Pay to provide the Services. We reserve the right to identify you as the person who has made the referral in any messages that are sent to them. We use Third-Party Data to (1) contact such third party using the Third-Party Data provided, and/or (2) provide you with an editable template message designed to facilitate communication between you and such third party through the Services. In addition to sending the foregoing communications, we may also send reminders or related messages to you and to third parties on your behalf from time to time where permitted by applicable law. In each case, any such communications sent to third parties using Third-Party Data will provide a means to "opt out" of receiving further communication of the same nature.

5. 5.Sensitive information:

   You can also provide us with information about yourself or third parties that is considered sensitive, such as political opinions, health information or religious beliefs. When you provide such information to us directly, we may seek your consent, where appropriate, to process this information, unless you choose to provide such information to be published publicly in relation to your donation or otherwise .

   We collect the information listed in this section for the purposes described below in the section “Our Use of Information Collected”. While you are under no obligation to provide us with such information, should you choose to withhold such information, we may not be able to provide you with some or all of the Service s.

Information That is Passively or Automatically Collected:

1. 1.Device & Usage Information:

   When you interact with Legash Pay through the Services, we automatically receive and store certain information from devices that you use to access the Services. This information is collected passively by using various technologies, and includes the type of internet browser or mobile device you use, any website from which you have come to the Services, your operating system, and location data through an IP address that identifies the city and state where you logged into the Platform or your precise geo-location if you have permitted your mobile device to provide that information to us.

   Legash Pay either stores such information itself or such information is included in databases owned and maintained by Legash Pay, or its agents or service providers. Furthermore, Legash Pay is compliance with the GDPR, CCPA, LGPD, and other countries privacy protection regulations.

2. 2.Aggregated Data:

   In an ongoing effort to better understand the use of our Services and serve you, Legash Pay often conducts research on its customer demographics, interests and behavior based on information we collect. We can de-identify and aggregate the information collected through the Services for research purposes or any other purposes, and we can share this information with our affiliates, agents, business partners, or other third parties (e.g., Google Analytics ).

3. 3.Cookies and Other Electronic Technologies:

   When you interact with the Services, we try to make that experience simple and meaningful. When you visit our Platform, our web server, third party business providers, and/or the social networking services integrated into the Service, use cookies or other electronic technologies (such as web beacons or pixel tags) for various purposes. Cookies are small pieces of information that are issued to your computer or mobile device when you visit a website or access or use a mobile application, and that store and sometimes track information about your use of the Platform. Web beacons are transparent image files, which enable the Platform to track website usage information. Unlike cookies, web beacons are not placed on your computers. Pixel tags are tiny graphic images with unique identifiers that track online movements of our use rs

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Legash Pay uses the information collected from the Services in a manner that is consistent with this Policy. We use the information that you provide (or otherwise permit the Services to access) for the following purposes

1. 1.Communicating with You

   We use the information we collect to contact you for administrative purposes (e.g., to provide services and information that you request or to respond to comments and questions). For instance, if you contact us by email, we will use the information you provide to answer your question or resolve your problem.

   We also use the information we collect to send you communications relating to the Services, such as updates on promotions and events, communications relating to products and services offered by us and by third parties, and communications about services we believe will be of interest to yo u.

   Mobile Services: If you access the Services through a mobile device and if you have chosen to provide us with your mobile number, or other electronic means to your mobile device, you agree that we can communicate with you regarding Legash Pay by SMS, MMS, text message. In the event you change or deactivate your mobile telephone number, you agree to promptly update your Legash Pay account information to ensure that your messages are not misdirected. Please note that your wireless service carrier’s standard charges, data rates, and other fees may apply where you access the Services through a mobile device. In addition, downloading, installing, or using certain Services on a mobile device may be prohibited or restricted by your carrier, and not all Services may work with all carriers or devices.

2. 2.Analytics and Product Development

   We use the information we collect to analyze data usage trends and preferences in order to improve the accuracy, effectiveness, security, usability or popularity of our Services .

3. 3.Customization

   We use the information we collect, such as device identifiers, to learn how users interact with our Services in order to personalize the content of our Services, such as customizing the language and causes on our homepage based on your location .

4. 4.Legal

   We use information we collect to defend our legal rights, comply with state, local, federal or international laws, and enforce our Terms of Service and this Policy .

CHILDREN’S PRIVACY

We do not knowingly collect any information from anyone under 16 years of age. Our website, products and services are all directed to people who are at least 16 years old or older .

If you are under 16, do not use or provide any information on this website or on or through any of its features/register on the website, make any purchases through the website or provide any information about yourself to us, including your name, address, telephone number or email address.

If we learn we have collected or received personal data from a child under 16, we will delete that information.

If you believe we might have any information from or about a child under 16, please contact us

DISCLOSURE OF INFORMATION

There are certain circumstances in which we share information collected through the Services with certain third parties without further notice to you, as set forth below.

• 1.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, similar event, or steps taken in anticipation of such events (e.g., due diligence in a transaction), user information may be part of the transferred asset s.

• 2.Affiliates and Subsidiaries:

  We share your personal information among the Legash Pay entities, including our affiliates and subsidiaries, in order to provide our Services including: hosting, marketing and publicizing causes; providing you with customer support; administering funds in connection with causes, sweepstakes, challenges or games; authenticating donors; sending you communications; and conducting the other activities described in this Policy.

• 3.Agents, Consultants, Vendors and Related Third Parties:

  Legash Pay sometimes hires other companies to perform certain business-related functions on Legash Pay’s behalf, and we provide access to or share your information with these companies so they can perform services for us. Examples of such functions include marketing, mailing information, data storage, security, fraud prevention, payment processing, legal services, and maintaining databases. We will collect, process and store your information on behalf of Legash Pay. We limit the personal information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information .

• 4.Legal Requirements:

  Legash Pay can access, disclose, transfer and preserve your information when we have a good faith belief that doing so is necessary to: (i) comply with the law including with subpoenas, search warrants, court orders, and other legal process; and respond to inquiries or requests from government, regulatory, law enforcement, public authorities, or content protection organizations; (ii) protect and defend the legal rights, privacy, safety or property of Legash Pay, its affiliates, subsidiaries, employees, agents, contractors, or its users; (iii) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages we may sustain; or (iv) enforce this Policy or any applicable Terms of Service.

• 5.Cause Organizers and beneficiaries of causes:

  We share your information with cause organizers and, if not the same, the beneficiaries of the cause. For example, if you donate to a fundraising cause, we share your name, email address and other information you’ve provided in connection with your donation with the cause organizer, who may contact you. For example, when you donate for a cause, then the cause organizer can receive donor information. In addition, beneficiary may communicate with you about your donation and/or may rely on your information in order to comply with its legal and auditing requirements.

• 6.Your consent

  We may share your information in the event that you consent to the sharing of your information. For example, we may partner with third party organizations to arrange for specific causes. If you consent to our delivering your contact information to a specific partner, we share, with the partner organization, your name, email address and other information you’ve provided in connection with your donation to the specific caus e.

• 7.Aggregate and/or De-Identified Information

  We aggregate and/or de-identify your information so that the information no longer relates to you individually. We may use and disclose aggregate and de-identified data for any lawful purpose.

• 8.Cookies and Other Electronic Technologies

  Information is shared as stated in the Section entitled “Cookies and Other Electronic Technologies”.

• 9.Other

  Users of Our ServicesWe provide your information to other users of our Services if you choose to make your information publicly available in a publicly accessible area of the Services in the comment s.

UNSOLICITED INFORMATION

Please be advised that some information you provide may be publicly accessible, such as information posted in forums or comment sections. We also collect information through customer support communications, your communication to us of ideas for new products or modifications to existing products, feedback and other unsolicited submissions (collectively, with publicly-accessible information, "Unsolicited Information"). By sending us Unsolicited Information, you further (a) agree that we are under no obligation of confidentiality, express or implied, with respect to the Unsolicited Information, (b) acknowledge that we may have something similar to the Unsolicited Information already under consideration or in development, (c) grant us an irrevocable, non-exclusive, royalty-free, perpetual, worldwide license to use, modify, prepare derivative works, publish, distribute and sublicense the Unsolicited Information, and (d) irrevocably waive, and cause to be waived, against Legash Pay and its users any claims and assertions of any moral rights contained in such Unsolicited Information. This Unsolicited Information section shall survive any termination of your account or the Services.

LINKS TO OTHER WEB SITES

This Policy applies only to the Services. The Services can contain links to other web sites not operated or controlled by Legash Pay (the "Third party"). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that Legash Pay endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their respective privacy policies.

DATA SECURITY

Legash Pay has implemented technical and organizational security measures to protect the information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, limiting access to information only to employees and authorized service providers who need to know such information for the purposes described in this Policy. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any information to Legash Pay via the Internet.

RETENTION OF YOUR INFORMATION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we 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 process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

POLICY CHANGES

This policy replaces all previous disclosures we may have provided you about our information practices. We reserve the right to change this policy, and to apply any changes to information previously collected, as permitted by law. If there are material changes to this policy or our information practices change in the future, we will notify you by posting the policy changes on our website.