Privacy Policy

Last updated: August 12, 2026

1. Information We Collect

We collect and use several types of information from and about you, including:

1.1 Personal Information

Information that identifies, relates to, describes, references, or can reasonably be linked - directly or indirectly - to an individual ("Personal Information").

1.2 Non-Personal Information

Information that does not directly or indirectly identify an individual, including demographic data, statistics, and aggregated data. Aggregated or statistical data may be derived from Personal Information but does not itself identify a specific individual.

1.3 Technical Information

Information about your device and internet connection, including:

  • Internet Protocol (IP) address
  • Login information
  • Browser type and version
  • Time zone setting
  • Browser plug-ins
  • Operating system and platform

1.4 Website Usage Information

Information about how you interact with our Website, including:

  • Full URLs, clickstream data, and navigation paths
  • Date and time of visits
  • Pages viewed or searched
  • Page response times and download errors
  • Length of visits
  • Interaction data (scrolling, clicks, mouse-overs)

1.5 Exclusions

Personal Information does not include:

  • Publicly available information from government records
  • De-identified or aggregated information

If non-personal or technical information is combined with Personal Information in a way that identifies an individual, we treat the combined information as Personal Information.

1.6 Identity Information for Signed Donation Agreements

Where a donation reaches an amount for which the receiving organization requires a signed donation agreement, we collect the information needed to prepare that agreement and to identify the person signing it:

  • Full name of the person or authorized representative signing
  • National personal identity code, where the donor is an individual
  • Company name, registration or tax identification number, and registered address, where the donor is a legal entity
  • Email address, used to deliver the agreement for signature

This information is collected to perform the donation agreement between you and the receiving organization, and to meet the record-keeping obligations that apply to it. Where a national personal identity code is collected, it is used only to identify the signatory within that agreement. It is not used for any other purpose, it is not used to match you against other records, and it is never shared with advertisers or sold.

A signed agreement is not required for every donation. The threshold is set by each receiving organization, and below it you are never asked for identity information.

2. How We Collect Personal Information

2.1 Information You Provide Directly

We collect information that you voluntarily provide, including:

  • Information submitted through Website forms
  • Correspondence records, including email communications
  • Search queries conducted on the Website
  • Information submitted when reporting issues or requesting support
  • Requests for additional services
  • Survey responses
  • Information used to create and manage user accounts
  • Subscription and service enrollment information
  • Transaction and billing details, including financial information
  • Chat transcripts and information shared through chat features
  • Information provided through other interactive Website features

User Contributions

Information you post publicly or share with others through the Website ("User Contributions") is shared at your own risk. While privacy settings may limit access, no security measures are perfect, and we cannot guarantee unauthorized access will not occur.

2.2 Automated Data Collection

As you navigate and interact with the Website, we may automatically collect:

  • Traffic data, logs, and usage patterns
  • Location and communication data
  • IP address, browser type, and operating system

This information allows us to:

  • Store user preferences
  • Recognize returning users
  • Improve Website performance and usability
  • Estimate audience size and usage patterns

Technologies Used

  • Cookies: Small data files stored on your device. You may refuse cookies through browser settings, but some Website features may not function properly.
  • Tracking Pixels and Web Beacons: Used to measure Website usage, email engagement, and system integrity.
  • Analytics and Session Measurement Software: We use analytics and session measurement tools to understand how our pages are used - which pages are visited, how long they take to load, and where people run into difficulty. Depending on the tool, this can include recordings of interactions on a page, such as clicks, scrolling, and typing. The tools we use for this are named individually in section 3.

2.3 Information from Third Parties

We may receive information from third parties, including:

  • Our payment processor, in relation to donations and payouts
  • Identity and sanctions screening carried out during organization onboarding
  • Public registers maintained by state authorities
  • Sign-in providers, where you choose to sign in with an external account

2.4 Third-Party Tracking Technologies

Some of the tools named in section 3 set their own cookies or use similar technologies when you visit our Website. We do not use advertising networks, we do not take part in interest-based or cross-site advertising, and we do not allow third parties to collect information on our Website for their own advertising purposes.

3. How We Share Your Information

We share Personal Information only where it is needed to operate the platform, where the law requires it, or where you ask us to.

3.1 Service Providers

We use the following service providers. Each processes information on our instructions, under a written agreement, and only for the purpose shown.

Provider Purpose Processing location
Stripe Payment processing, payouts, and identity verification of organizations European Union and United States
SignNow Electronic signing of donation agreements United States
Mailgun Delivery of receipts, notifications, and newsletters European Union
Cloudflare Website delivery, security filtering, bot protection on the sign-in and registration forms, and approximate location detection Global network, including the United States
Google Optional sign-in, address suggestions, and website analytics European Union and United States
Ahrefs Website traffic measurement European Union
Contentsquare Measurement of how pages are used, including interaction recordings European Union
Sentry Detection and diagnosis of technical faults European Union and United States
ip-api.com Approximate country detection, used only when it cannot be determined otherwise United States
Photon (Komoot) Address suggestions, used as an alternative to Google European Union
Anthropic, Google Automatic translation of organization profile text into the languages we support United States

This list reflects the providers in use when this policy was last updated. We update it when a provider is added or replaced.

3.2 Receiving Organizations

When you donate, your donation is received by the organization you chose, not by us. That organization can see what you provided when donating - your name, email address, the amount, and any message you wrote - and it decides how that information is used for its own purposes, such as thanking you or sending you its newsletter. Its own privacy notice applies to that use. The terms on which we handle donor information on an organization's behalf are set out in our Data Processing Agreement.

3.3 Public Authorities

We disclose information to public authorities where the law requires it. This includes checks against public registers maintained by state authorities when an organization is verified, and responses to lawful requests from supervisory, tax, or law enforcement bodies.

3.4 What We Do Not Do

We do not sell Personal Information. We do not share it with advertising networks or data brokers. We do not share donor information with other organizations on the platform.

4. Purpose for Collection and Use

We use Personal Information for the following purposes:

  • To operate and present our Website
  • To provide requested products or services
  • To process transactions and payments
  • To prepare and deliver signed donation agreements where required
  • To respond to inquiries and provide customer support
  • To enforce contracts, billing, and collection
  • To prevent fraud and unauthorized transactions
  • To notify you of changes to services or policies
  • To enable participation in interactive Website features
  • To comply with legal obligations and law enforcement requests
  • To evaluate corporate transactions (e.g., mergers, restructuring)
  • For marketing communications, subject to your consent
  • For any other purpose disclosed at the time of collection
  • For any purpose with your consent

If you no longer wish to receive marketing communications, you may opt out by contacting us.

5. Legal Basis for Processing (GDPR & Global Equivalents)

Where required by law, we process Personal Information under the following legal bases:

  • Consent - Article 6(1)(a) GDPR
  • Performance of a Contract - Article 6(1)(b) GDPR
  • Legal Obligation - Article 6(1)(c) GDPR
  • Vital Interests - Article 6(1)(d) GDPR
  • Public Interest or Official Authority - Article 6(1)(e) GDPR
  • Legitimate Interests - Article 6(1)(f) GDPR, where not overridden by user rights

Equivalent legal bases apply under other global privacy laws, including UK GDPR (United Kingdom General Data Protection Regulation), LGPD (Lei Geral de Proteção de Dados — Brazil's General Data Protection Law), PIPEDA (Personal Information Protection and Electronic Documents Act — Canada), and CPRA (California Privacy Rights Act — United States).

6. International Data Transfers

Some of the service providers named in section 3 are located in, or process information in, countries outside the European Economic Area - in particular the United States. This applies to payment processing, the electronic signing of donation agreements, fault monitoring, and the automatic translation of organization profile text. Where information is transferred outside the European Economic Area, we rely on the following safeguards:

  • Standard Contractual Clauses
  • Equivalent legal mechanisms
  • Contractual and technical protections with service providers

7. Your Privacy Rights (Global)

Depending on your location, you may have the right to:

  • Access your Personal Information
  • Correct inaccurate or incomplete data
  • Request deletion or erasure
  • Restrict or object to certain processing activities
  • Request data portability
  • Withdraw consent where applicable
  • Lodge a complaint with a data protection authority

Requests may be submitted using the contact details provided in this Privacy Policy.

Where your request concerns a donation, the organization that received it decides how your information is used for its own purposes. We will pass your request on to that organization and assist it in responding.

8. Data Retention

We retain Personal Information only as long as reasonably necessary to:

  • Fulfill the purposes outlined in this Privacy Policy
  • Comply with legal, regulatory, tax, and accounting obligations
  • Enforce agreements and resolve disputes

In practice we apply the following retention periods:

Information Retention period
Account information While the account is open, and for 12 months after it is closed
Donation and payment records 5 years, as required by accounting and tax law
Signed donation agreements and the identity data within them 10 years, matching the period in which a claim under the agreement may be brought
Newsletter subscription records Until you unsubscribe, and for 12 months afterwards as evidence of the subscription
Approximate location detected from your IP address 24 hours
Security, access, and technical fault logs 12 months
Support correspondence 24 months from the last message

Where a longer period is required by law, or where information is needed for an ongoing dispute, we keep it for as long as that requirement or dispute lasts and no longer. Once a period ends, the information is deleted or anonymized so that it can no longer be linked to you.

9. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect Personal Information. However, no system is completely secure, and we cannot guarantee absolute security.

10. Children's Privacy

Our Website and services are not intended for children under 13. We do not knowingly collect Personal Information from children under 13. If such information is identified, we will delete it promptly. Higher age thresholds apply where required by law.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes become effective when posted. Where required by law, notice of material changes will be provided.

12. Contact Us

If you have questions about this Privacy Policy, please contact us at:

service@holydonation.com

If you are an organization receiving donations through the platform, the terms on which we process donor information on your behalf are set out in our Data Processing Agreement.

Cookie Notice

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