Last updated: 18 June 2020
shares and protects personal information from its users and the legal basis for doing so.
Please note that while Givling is a for-profit business, it does not exceed any of the thresholds for application of
the California Consumer Privacy Act (CCPA). Givling does not sell your personal information.
("Policy"). To use the Givling website or mobile app, you need to submit personal information such as during your
account registration. By setting up an account or using any part of the Givling services, you consent to the
collection, use, and disclosure of your information as outlined in this Policy. Additional personal information may
be required for game winners and debtor participants to receive monetary prizes. Givling will inform the user,
winners or debtors regarding the information it requires and will only use this information for the stated
purpose(s), such as administering the game of skill and crowdfunding activities. By providing the information, a
user is giving consent to Givling, Inc. to use the information for the stated purpose(s); if the user does not
provide the information, features of the website or monetary prizes will not be available to the user.
Your submission of personal information is voluntary. When you voluntarily submit information, you consent to the
use of your information for the purpose(s) stated in the Terms & Conditions including participating in a game and
crowdfunding loan debts. Givling services are not available in Europe and we do not store or transfer information
internationally, therefore, Givling is not obligated to comply with EU General Data Protection Regulation 2016/679
(the "GDPR"). Notwithstanding, users are hereby informed of the following:
- the data controller is Gannett Peak Technical Services and can be reached at the address 1709 Carey Ave,
Suite 1, Cheyenne, WY 82001-4442. Any information provided to Givling is stored at Green House Data of 340
Progress Circle, Cheyenne, WY 82007; and,
- if you are absolved under the law from giving consent to this Policy, you nevertheless acknowledge you have
read and understood its terms.
Information Collected and Stored
In order for you to create an account with Givling, participate in the game, or take part in crowdfunding
activities, we need to collect and process certain information. Personal information which may be collected and some
of which may be required to register an account or for use of an account includes:
Givling also collects personal information for winners and debtors to provide payments and comply with tax
reporting. In those cases, additional information collected may include:
- User Name, alias allowed
- Email address
- Phone number
- Zip code
- Internet protocol (IP) address
- Some uniform resource locators (URLs)
- Device identifiers
- Installed apps lists and usage stats
- App crash reports
- Browsing history
- Individual game participation records, such as scores, times of play, and game results
- Overall game records such as scores, times of play, and game results, and
- Any information you choose to provide us (such as a profile picture).
All information collected by Givling is stored by Green House Data of Cheyenne, WY and Givling utilizes the services
of Gannett Peak Technical Services of Cheyenne, WY to act as its data controller. While we do not store credit card
or banking information, such information from time to time may be entered by you into PayPal's payment processing
system. PayPal or Givling will notify you via your email on file if we become aware of any security breach that
might compromise your personal information. If you have any questions about, or wish to review or correct the
information we maintain about you, you may send an email to email@example.com.
- Legal name
- Social Security Number
- Date of birth
- Photos uploaded or provided to us
- Debt holder information
- Debtors account number
- Educational lending institution information
- Other information that may be required by the IRS or other authorities.
Our Use of Information
Givling uses the collected information for various purposes including:
Givling may also use information for the purpose of information storage and access; personalization; ad selection,
delivery, and reporting; and measurement. In support of these services, some partners may use some or all of the
following features: precise geographic location data; matching date to offline sources; or linking devices.
- To administer a game of skill
- To administer crowdfunding services
- To monitor jurisdictions of users for compliance with Federal and State Laws
- To contact or identify you
- To notify you about changes to our services
- To notify game victors, drawings recipients and debtors selected to be funded
- To transmit payments and tax reporting
- To provide customer support
- To gather analysis or valuable information so that we can improve our services
- To detect, prevent and address rules violations, technical issues, or disputes
- To defend our legal rights, comply with state, local, federal or international laws, and enforce our Terms
of service and this Policy.
There are certain circumstances in which we share information collected through the services with certain third
parties without further notice to you. The first circumstances may occur as we develop our business, in which case
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. The second instance may occur if we hire agents, consultants,
vendors and related third parties to perform certain business-related functions on Givling's behalf, and we provide
access to or share your information with these companies so they can perform services for us. 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.
Publicly Disclosed Information
Without additional notice to you, Givling will publicly disclose game records such as names, towns, and states of
winners and recipients of funding according to the Terms and Conditions which you have agreed to by accessing our
services and playing the game.
You can post comments, leave feedback, send thank-you notes or otherwise communicate with other users through
Givling. Any content, including such comments, feedback, and notes are your choose to post through Givling 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). 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 Givling, and to remove postings or content that may be viewed as inappropriate or offensive to others.
Legal Basis for Collecting and Processing Personal Information
Givling's legal basis for collecting and using the personal information described in this Policy depends on the
personal information collected and the specific context in which we collect the information, but the legal basis may
include one or more of the following:
- You have given Givling permission to process personal information
- Givling needs to perform a contract with you
- Processing your personal information is in Givling's legitimate business interests
- Givling needs to comply with legal obligations such as IRS reporting
- Processing is necessary to protect your vital interests, demonstrate the integrity of the game, and the
People under 18 years of age (or the legal age of majority in your jurisdiction) are not permitted to use Givling.
Givling does not knowingly collect any personal information from children under the age of 18 and children under 18
are not permitted to register for an account or use our services.
If you believe that a child has provided us with personal information, please contact us at firstname.lastname@example.org. If
we become aware that a person under age 18 has provided us with personally identifiable information, we'll delete
Retention of Personal Information
Givling will retain your personal information for as long as is necessary for the purposes set out in this Policy
which may be indefinitely. Givling will retain and use your information to the extent necessary to comply with our
legal obligations, resolve disputes, and enforce our policies. When determining the retention period, we take into
account various criteria, such as the type of services requested by or provided to you, the nature and length of our
your use of our services, possible re-enrolment with our 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
This Policy informs you about the categories and specific pieces of personal information collected by Givling, how
it uses the information, and identifies the third parties with whom the information is kept. By visiting your
"Account Settings" portion of Givling, you can access, review, and correct or change the personal information
Givling holds about you. You can also make a written request via the address listed below that, within 45 days, we
provide copies in a readily portable format of personal information about you held by us. If that information is
inaccurate, it is your responsibility to inform Givling of the inaccuracies at the same address and we will endeavor
to make the necessary amendments. You have the right to object to Givling's use and storage of your information and
may request that we erase, do not process, or otherwise block specific personal information about you, subject to
our legal justifications for retaining copies of the information; please note, should you choose to delete or
restrict such information, we may not be able to provide you with some or all of the services.
Information Passively and Automatically Collected
Givling uses commercial software products, such as Fabric.io, to track usage numbers and events within the mobile
app, analyze and report on aggregated web metrics data. This data is generally retained indefinitely to support the
website and mobile app.
When you use Givling, 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 Givling or your precise
geo-location if you have permitted your mobile device to provide that information to us. Givling either stores such
information itself or such information is included in databases owned and maintained by Givling, or its agents or
In an ongoing effort to better understand the use of our services and serve you, Givling 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).
When you use the services, the services request that you provide your city or town and state of residence. Please
keep in mind that other users of the services can view your city or town and state of residence, if it is made
available within Givling's settings. 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.
Links to Other Websites
to other websites that are not operated or controlled by Givling (the "Third-Party Sites," sometimes called
"Partners"). The policies and procedures set forth herein do not apply to the Third-Party Sites. The availability of
Third-Party Sites through Givling does not imply that Givling endorses or has reviewed the Third-Party Sites.
Givling will not provide or sell your information to such Third-Party Sites or other third parties. We suggest
contacting those sites directly for information on their respective privacy policies.
When you use Givling, our web server sends a cookie to your computer or mobile device. This is in an effort to make
your experience simple and meaningful. "Cookies" are small files that a website transfers to a user's computer to
allow the site to remember specific information. Cookies store and sometimes track information about your use of our
services. If you do not want cookies to be transferred to your computer, you may choose to opt out of their use by
modifying browser options. While you will still be able to access most features of the website or mobile app,
certain features may not work as well or may be unavailable to you.
Givling may use certain types of information-collecting tools on its various websites including:
Givling uses session cookies on its website for technical purposes such as to enable a user to more easily navigate
the game. Session cookies only collect non-personally identifiable data, and once a user closes his or her browser,
the session cookies disappear.
Persistent cookies store information on a user's computer for longer periods of time than session cookies, and the
information is stored across multiple sessions. Givling never uses persistent cookies to collect personally
identifiable information about its website visitors. Givling may use persistent cookies to improve its web metrics
by distinguishing between new and returning visitors; to aggregate data anonymously on how visitors use the
services; and to "remember" preferences that users provide voluntarily.
Customization tools may allow users to voluntarily provide information to personalize and improve their online
experience on a particular site. This information is saved on the Givling's contracted servers.
Some cookies may be necessary to make our services available to you ("Functional cookies"). For example, to provide
the login functionality and to remember your consent and privacy choices. We may not be able to provide our services
without Functional cookies.
cookies"). Some of the Analytical cookies used are set by us, and some are set by third parties such as Google
Analytics or Fabric.io, 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/.
We may also work with third-party advertising companies to show you ads we think may be of interest to you and to
track sales from ads for our services. For example, we may show you ads about our services on third party websites
and apps, or ads about third parties' products and services on our website and app. To do so, we and our advertising
partners place and access cookies through our services and otherwise collect or access personal information
collected over time and across different online services. For example, we may use Google Analytics Advertising
Features, such as, Google AdWords and Double Click. You can opt out of the Google Analytics Advertising Features via
including to: (1) allow you to navigate and use all the features provided by our services; (2) customize elements of
the layout and/or content within our services and remember that you have visited us before; (3) identify the number
of unique visitors we receive; (4) improve our services and learn which functions of our services are most popular
with users; and (5) how you use our services (e.g., by learning how long you spend using our services and where you
have come to our services from. As we adopt additional technologies, we may gather additional information through
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 Explorer; Google
Chrome; Mozilla 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 our 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.
Other technology: Web beacons
A web beacon is a transparent image file. Web beacons enable websites 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 our services. 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.
Other technology: Pixel Tags
In addition, we may use pixel tags or similar technologies (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.
Givling has implemented technical and organizational security measures to protect the information provided 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 our 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
Givling via the Internet.
Givling 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.
3rd Party Privacy Policies
Givling works with other technologies and networks, each which may have their own privacy policies, including this
one from Pollfish:
Survey Serving Technology
This app uses Pollfish SDK. Pollfish is an on-line survey platform, through which, anyone may conduct surveys.
Pollfish collaborates with Developers of applications for smartphones in order to have access to users of such
applications and address survey questionnaires to them. When a user connects to this app, a specific set of
user’s device data (including Advertising ID which will may be processed by Pollfish only in strict compliance
with google play policies- and/or other device data) and response meta-data is automatically sent to Pollfish
servers, in order for Pollfish to discern whether the user is eligible for a survey. For a full list of data
received by Pollfish through this app, please read carefully Pollfish respondent terms located at https://www.pollfish.com/terms/respondent. These data
will be associated with your answers to the questionnaires whenever Pollfish sends such questionnaires to
consent for the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may
disable Pollfish operation at any time by using the Pollfish “opt out section” available on Pollfish website .
way Pollfish works.
Givling encourages users to review all 3rd Party Privacy Policies carefully.
automatic contact form within the Givling App or at www.givling.com.
You may also contact us in writing at:
P.O. Box 9149
Jackson, WY 83002.