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Privacy Policy

Last Updated: September 30, 2014

We recognize that your privacy is very important and take it seriously.  This Privacy Policy describes the GIIN’s policies and procedures on the collection, use and disclosure of your information when you use the Site, as defined below.  This Privacy Policy governs and all pages within owned or operated by the GIIN, including but not limited to http://www.iris.thegiin.org, or that are accessible with or without a username and password, including but not limited to text, content, photographs, video, audio, graphics and services (collectively, this “Site”).  Please read this Privacy Policy carefully before you start to use the Site.  By using the Site or participating in certain of the GIIN’s programs, including but not limited to ImpactBase and the Impact Reporting and Investment Standards (“IRIS”) Data Submission Center, you signify your acceptance of this Privacy Policy and the terms of our Terms of Use.  If you do not agree to this Privacy Policy, you should elect not to visit the Site.

We will not use or share your information with anyone except as described in this Privacy Policy.  This Privacy Policy does not apply to information we collect by other means (including offline or in accordance with other agreements that you may enter into with the GIIN) or from other sources.  Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use.

You should review this Privacy Policy carefully.  By using any part of the Site, you accept and agree to the terms of this Privacy Policy and our Terms of Use.

Although the GIIN will use commercially reasonable efforts to safeguard your personal information, transmissions made by means of the Internet cannot be made absolutely secure.  The GIIN will have no liability for disclosure of personal information due to errors in transmission or unauthorized acts of third parties.

1.       Safe Harbor: The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "U.S.-EU Safe Harbor Framework") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The United States Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles and frequently asked questions (the "U.S.-Swiss Safe Harbor Framework") to satisfy a similar requirement under Swiss law regarding personal information transferred from Switzerland to the United States. Consistent with its commitment to protect personal privacy, the GIIN adheres to the U.S.-EU Safe Harbor Framework and U.S.-Swiss Safe Harbor Framework (collectively, "Safe Harbor Frameworks").

2.       User-Provided Information.

a.      We may 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 this information may be downloaded or exported by the public from the Site.  We may also periodically provide this information to third party contractors and partners for purposes consistent with our mission.

b.       Additionally, the Site may contain message boards, chat rooms, forums, bulletin boards and other interactive features that allow you to post, submit, publish, display or transmit to other users' content or materials on or through the Website.  Such information may be available to and searchable by the public on the Site.

c.      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.  You shall be responsible for maintaining the confidentiality of your Registration Data.  We will use commercially reasonable efforts to safeguard such information.  You shall notify the GIIN in a timely manner of any known or suspected unauthorized use of your account, or any known or suspected breach of security, including loss, theft, or unauthorized use or disclosure of your password.  You are responsible for all usage or activity on your account, including use of the account by any third party authorized by you to use your username and password.  The GIIN reserves the right to terminate your account at any time, or to modify or discontinue ImpactBase or the Services, each in the GIIN's sole discretion.

d.      You may be asked to provide us with information about yourself if you register for a member account with the Site, or for inclusion in a member profile or membership directory, such as the name and email address of a primary contact person.  If you provide the Site with that information, such 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.  We will compile, process, and use the information on your member profile only for the purposes of creating, maintaining, and making available the member directory and search functionality to our paid members.  Additionally, we may use your email address to send you Site-related notices (including any notices required by law, in lieu of communication by postal mail).  We may also use your contact information to send you marketing messages.  If you do not want to receive such messages, you may opt out by following the instructions in the message, or by contacting us at [email protected].  If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.

e.        You may be asked to provide us with other information about yourself, such as your address or the address of a contact person, your fax number, and your credit card information. We will use such information only for the purpose of providing you services or content you request from us. We do not store or retain your credit card information; we use a secure third-party service provider to process your credit card information which is not permitted to store, retain, or use billing information except for the purpose of credit card processing on the GIIN's behalf.

f.       You can review, update, or remove the information you included in your member profile by logging into the Site, visiting your member profile page, and making changes.  You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us or to opt out of providing a member profile.  Such requests will be honored within 10 business days.

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

4.       Cookies.  When you visit the Site, we may send one or more “cookies” - small data files - to your computer to uniquely identify your browser and let the GIIN help you log in faster and enhance your navigation through the Site.  A cookie may convey anonymous information about how you browse the Site to us, but it does not collect personal information about you.  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.  Persistent cookies can be removed by following your web browser’s directions.  A session cookie is temporary and disappears after you close your browser.  You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent.  However, some features of the Site may not function properly if the ability to accept cookies is disabled.

5.       Log files.  Log file information is automatically reported by your browser each time you access a web page.  When you use the Site, 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.

6.       Clear GIFs Information.  When you use the Site, we may employ clear GIFs (also known as web beacons) which are used to track the online usage patterns of our users anonymously.  No personally identifiable information is collected using these clear GIFs.  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.

7.       Uses of Information.  We use information that we collect about you or that you provide to us, including any personal information, in the following ways:

a.       To present the Site and its contents in a suitable and effective manner for you and for your computer;

b.      To provide you with information, products or services that you request from us (that you may opt out of via instruction in email messages);

c.       To carry out our obligations and enforce our rights arising from any contracts entered into between you and us; and

d.      To notify you about changes to the Site at our discretion.

8.       Third Party Services.

a.       Personally Identifiable Information.

i.      We will only disclose personally identifiable information we collect from you to third parties without your permission to the extent necessary to: (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; (C) to enforce any terms of service on the Site; (D) to provide you with the services or products requested by you and to perform other activities related to such services and products, including billing and collection; (E) in connection with a merger, acquisition, or liquidation of the GIIN, or (F) to operate the GIIN’s systems properly.

ii.      We may store personal information in locations outside the direct control of the GIIN (for instance, on servers or databases collocated with hosting providers). We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution.

iii.      We may share or disclose your information with your consent, such as if you choose to sign on to the Site through a third-party service.

iv.      We cannot control third parties’ use of your information.

v.      The GIIN may disclose your personal information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect the GIIN’s rights or property.

b.      Non-Personally Identifiable Information.  We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain of the GIIN’s services.

9.       Protection of Your Information.  In order to protect your personal information, the GIIN has put in place what the GIIN believes to be reasonable physical, electronic and managerial procedures to safeguard and secure your personal data.  However, no assurances can be given that these security measures will prevent any unauthorized interception of or access to your personal data and you hereby agree not to hold the GIIN liable for use of your personal data obtained in any unauthorized manner.

10.   Privacy of Children.  The GIIN does not knowingly collect or solicit personal information from anyone under the age of thirteen (13) or knowingly allow such persons to register with the Site.  If we become aware that we have collected personal information from a child under age of thirteen (13) without verified parental consent, we will delete that information from the Site.

11.   Dispute Resolution: Disputes regarding this Privacy Policy will be resolved through the American Arbitration Association dispute resolution process, as part of the GIIN's compliance with the Safe Harbor Frameworks. If you feel that the GIIN is not abiding by its posted privacy policy or is not in compliance with the Safe Harbor principles, you should first contact the GIIN by email at [email protected].

12.   Changes to Privacy Policy.

a.       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.  Your use of the Site after such changes have been posted shall constitute your acceptance of the revised Privacy Policy.

b.      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 (GIIN)
Attn: Privacy
30 Broad Street, 38th Floor
New York, NY 10004