Date of Last Revision: May 14, 2020.

Welcome to the web sites, mobile application or widgets (as the case may be) operated by Invest In Me Limited. (including its subsidiaries, affiliates, agents, and service providers, collectively, “Invest In Me,” “we,” “us,” or “our”). Invest In Me provides (a) a platform through its website at www.invest-in-me.org and attendant mobile applications (the “Invest In Me Platform”) and related services (collectively the Invest In Me Platform, including any new features and applications, the “Invest In Me Services”). The Invest In Me Platform provides information about Invest In Me, and it explains how users can post a fundraising campaign, download a donation button, accept monetary donations and details our related services (together with the Platform, the “Services”) to users and visitors (“you” or “your”).

This Privacy Policy (the “Policy”) describes and governs how we collect, use, share and protect information collected in the context of our Services. Before you use or submit any information through or in connection with the Services, please carefully review this Policy. By using any part of the Services, you consent to the collection, use, and disclosure of your information as outlined in this Policy. To the extent allowed by law, the English version of this Policy is binding and other translations are for convenience only.

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 or device (e.g., by logging how you interact with our Services).

  1. Information That You Provide Directly to Us:
    1. Registration information:When you register for our Services or open an account, we collect your contact and login details, your zip code, your country and any information you choose to provide us (such as a profile picture). You can edit your information by logging into your account and making changes at any time. If you have any questions about, or wish to review or correct the information we maintain about you (a) on the Invest In Me Platform, please contact us.
    2. Creation of a fundraising campaign: When you create a campaign on our Platform , we collect the information you choose to provide us in relation to your campaign. For example, you can provide a campaign title, choose a campaign category, upload images and describe your campaign goal(s).Our payment processors collect and maintain information related to your withdrawal of funds from any campaign.
    3. Donation information: On the Invest In Me Platform, when you donate to a fundraising campaign, 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). Our payment processors collect your credit card details and other information necessary to process the donation.
    4. 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 that 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.
    5. Information relating to third parties: You can choose to provide us with information relating to third parties. For example, if you choose to share your campaign on the Platform with family and friends, we request access to information stored in your email and mobile device address books, such as names, email addresses, or phone numbers of your contacts (collectively, “Third-Party Data”). 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 campaign 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 Invest In Me 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.
    6. 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 campaign or 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 Services.
  2. Information That is Passively or Automatically Collected:
    1. Device & Usage Information: When you interact with Invest In Me 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. Invest In Me either stores such information itself or such information is included in databases owned and maintained by Invest In Me, or its agents or service providers.
    2. Aggregated Data: In an ongoing effort to better understand the use of our Services and serve you, Invest In Me 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. Location Information:When you use the Services to organize a fundraising campaign, the Services request that you provide your city or town and state or province of residence. Please keep in mind that other users of the Services can view your city or town and state or province of residence in connection with the campaign, if it is made available within Inivest In Me’s Public Search Directory. We also use your location information as described above under “Device & Usage Information”, and in an aggregate way, as described above in the “Aggregated Data” section.
    4. 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 sends a cookie to your computer or mobile device. 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.
      1. Type of cookies: Some cookies are strictly necessary to make our Services available to you (“Functional cookies”). For example, to provide the chat and login functionality and to remember your consent and privacy choices. We cannot provide our Services without Functional cookies. We also use cookies for analytics purposes in order to operate, maintain, and improve our Services (“Analytical cookies”). Some of the Analytical cookies used are set by us, and some are set by third parties such as Google Analytics, to collect and process certain analytics data on our behalf. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/.
      2. Why we use cookies: We use cookies and similar technologies to collect information about your access to and use of the Platform: including to: (1) allow you to navigate and use all the features provided by our Platform; (2) customize elements of the layout and/or content within the Platform and remember that you have visited us before; (3) identify the number of unique visitors we receive; (4) improve the Platform and learn which functions of the Platform are most popular with users; and (5) how you use the Platform (e.g., by learning how long you spend on the Platform and where you have come to the Platform from. As we adopt additional technologies, we may gather additional information through other methods. We will notify you of such changes as described in the “Changes to Invest In Me’s Privacy Policy” section below.)
      3. Your cookie preferences: Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers or mobile devices. You can also consult the “Help” section of your browser for more information (e.g., Internet ExplorerGoogle ChromeMozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services. If you are accessing our Services through a mobile device, you can also update your privacy settings on your device by setting the “Limit Ad Tracking” and Diagnostics and Usage setting property located in the settings screen of your Apple iPhone or iPad, or by resetting your Android ID through apps that are available in the Play Store. You can also limit information collection by uninstalling the App on your device and you can use the standard uninstall process available as part of your device for this purpose.
      4. Other technology
        1. Web beacons: A web beacon is a transparent image file. Web beacons enable the Platform to track website usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer. We may use them in association with cookies to understand how visitors interact with the pages and content on the pages of the Platform. We may also use web beacons to track whether you have opened an HTML email. When the email is opened, a part of the code that makes up the HTML page calls a web server to load the web beacon that then generates a record showing that the email has been viewed. Web beacons may also recognize when the email was opened, how many times it was forwarded and which URLs (links within the email) were clicked.
        2. Pixel Tags: In addition, we may use pixel tags (also referred to as clear gifs or web bugs). Pixel tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of our users. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly in web pages. Pixel tags also allow us to send email messages in a format users can read, and they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by pixel tags to information that is intended to identify our users.
  3. Information From or To Social Networking Services: One of the special features of the Services is that it allows you to enable or log into the Services via various social networking services like Facebook or Twitter, or upload videos using YouTube APIs (“Social Networking Service(s)”). By directly integrating these services, we aim to make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to provide your credentials for the applicable Social Networking Service in order to log in to our Services. When you add a Social Networking Services account to the Services or log into the Services using your Social Networking Services account, we will collect relevant information necessary to enable the Services to access that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service (for example, your name and photograph, as well as other information that you permit the Social Networking Service to share with us). We will use, store, and disclose such information in accordance with this Policy. However, please remember that the manner in which Social Networking Services use, store, and disclose your information is governed by the policies of such third parties, and Invest In Me shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Services. For example, if you upload a video onto your fundraiser using the mobile application for the Invest In Me Platform, your video will be uploaded using YouTube and subject to Google’s Privacy Policy and Google’s Security Settings. You also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you can post to Facebook that you performed an activity on the Platform). By proceeding, you are allowing the Social Networking Service to access your information on the Platform and you are agreeing to the Social Networking Service’s terms of use and privacy policy in your use of the Service. You further acknowledge that if you choose to use this feature, your friends, followers, and subscribers on any Social Networking Services you have enabled will be able to view such activity. Please visit the terms of use and privacy policy of the relevant Social Networking Service to find out more information about your rights and choices.

OUR USE OF INFORMATION COLLECTED

Invest In Me 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. Communicating With You:
    1. 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 you. For example, we can send periodic emails to registered users of the Services relating to their recent interactions with the Services, such as donating to a campaign or “hearting” a campaign.
  2. Mobile Services: 
    1. 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 Invest In Me by SMS, MMS, text message. In the event you change or deactivate your mobile telephone number, you agree to promptly update your Invest In Me 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. By using the Services on a mobile device, you agree that we may communicate with you regarding Invest In Me by SMS, MMS, text message, or other electronic means to your mobile device.
  3. Providing the Services:
    1. We use the information we collect to operate, maintain, and provide our Services such as enabling access to the Platform, customer support or to complete transactions.
  4. Analytics and Product Development:
    1. 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. If you are located in Europe, we process information as listed under A, B and C as necessary (i) to fulfill our obligations under our contract with you or in order to take steps at your request prior to entering into a contract, or (ii) for our legitimate interest, such as, to maintain our relationship with you or to protect you and us against fraud.
  5. Customization:
    1. 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 campaigns on our homepage based on your location. If you are located in Europe, we process information as listed under D as necessary for our legitimate interest.
  6. Legal:
    1. 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. If you are located in Europe, we process information as listed under E (i) to fulfill our obligations under our contract with you or in order to take steps at your request prior to entering into a contract; (ii) for our legitimate interest to maintain our relationship with you, (iii) to protect our business or protect you and us against fraud; or (iv) to comply with legal obligations.

OUR DISCLOSURE OF INFORMATION COLLECTED THROUGH THE SERVICES

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:
    1. 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 assets.
  2. Agents, Consultants, Vendors and Related Third Parties:
    1. Invest In Me sometimes hires other companies to perform certain business-related functions on Invest In Me’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 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.
  3. Legal Requirements:
    1. Invest In Me 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 Invest In Me, 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.
  4. Campaign Organizers and beneficiaries of campaigns:
    1. We share your information with campaign organizers and, if not the same, the beneficiaries of the campaign. For example, if you donate to a fundraising campaign, we share your name, email address and other information you’ve provided in connection with your donation with the campaign organizer or beneficiary, who may contact you.
  5. Your consent:
    1. 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 campaigns. 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 campaign.
  6. Aggregate and/or De-Identified Information:
    1. 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.
  7. Analytics:
    1. We use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Cookies and other electronic technologies” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive, and provide certain features to you. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. This information can be used to place interest-based advertisements on the Platform. This may result in you seeing advertisements for our Platform when you visit other websites. To prevent Google Analytics from using your information for analytics, you can install the Google Analytics Opt out Browser Add-on by clicking here. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
  8. Other Users of Our Services:
    1. We 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, such as in your campaign or in the comments.

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 Invest In Me 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.

CHILDREN

Our Services are not designed for use by individuals under the age of 13 (or 16 for children located in Europe). If you are under the age of 13 (or 16 for children located in Europe), please do not use the Services and/or submit any information through the Services. If you have reason to believe that a child under the age of 13 (or 16 for children located in Europe) has provided personal information to Invest In Me through the Services, please contact us at [email protected], and we will delete that information from our databases to the extent required by law.

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 Invest In Me (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that Invest In Me endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their respective privacy policies.

SECURITY

Invest In Me 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 Invest In Me via the Internet.

DO-NOT-TRACK SIGNALS

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.

RETENTION OF YOUR INFORMATION

We will only retain the information for as long as necessary for the purpose for which that information was collected and to the extent permitted or required by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take step to anonymize it so that you can no longer be identified from it in accordance with our internal document retention policies.

When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information about you, mandatory retention periods provided by law and the statute of limitations.

ACCESS TO INFORMATION

When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information about you, mandatory retention periods provided by law and the statute of limitations.

YOUR RIGHTS AND CHOICES

You can access and correct certain information about you by visiting the “Account Settings” portion of our Platform. You can control whether certain information you post to the Services is publicly available to others by adjusting the settings in your account. You can also request in writing copies of personal information about you held by us. If that information is inaccurate, please let us know and we will endeavor to make the necessary amendments, erase, or block the relevant information as you request.

OTHER TERMS

Your access to and use of the Services is subject to the Terms of Service and such other terms, which may be made available to you in connection with your use of the Services.

CHANGES TO INVEST IN ME’S PRIVACY POLICY

Invest In Me reserves the right to update or modify this Policy at any time and from time to time. We will notify you of any updates or changes we make to this Policy. If you disagree with our revisions to the Policy, you can deactivate your account or discontinue the use of our Services. Please review this Policy periodically for any updates or changes to this Policy.

If you are in Europe, you will not be required to agree to any changes to this Policy, but you do acknowledge that you have read and understood its terms.

CONTACTING INVEST IN ME

Please also feel free to contact us if you have any questions about Invest In Me’s Policy or the information practices of the Services.

You can contact us as follows:

Invest In Me Limited
P.O. Box 239, Waigani, National Capital District
Port Moresby, PAPUA NEW GUINEA

For the Invest In Me Platform, please contact us through here.