This planned giving website ("website") is hosted by Crescendo Interactive, Inc. ("Crescendo") on behalf of Holt International ("Subscriber" or "Subscribing Organization"). Holt International is offering the content of this website to its supporters, donors, prospects and certain professionals as an educational service concerning the planned giving topics presented on this website.
Use of this website, and the website's data collection practices, are subject to the terms of this Privacy Statement.
CONSUMER PRIVACY RIGHTS
This specific section of the Privacy Statement is adopted to comply with applicable state privacy laws. Applicable state privacy laws include: the California Consumer Privacy Act, as amended by the California Privacy Rights Act; the Colorado Privacy Act; Connecticut's Act Concerning Data Privacy and Online Monitoring; and the Virginia Consumer Data Protection Act.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("personal information").
Categories of personal information collected by this website from consumers within the last twelve (12) months include the following:
Personal Information Collected
||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, or other similar identifiers.
|B. Categories of Personal information
||A name, address, telephone number, or financial information.
|C. Categories of protected classifications under applicable state or federal law
||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, sex (including gender, gender identity, gender expression), sexual orientation.
|D. Commercial information
||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|E. Biometric information
||Physiological, biological, or behavioral characteristics, including an individual's DNA (deoxyribonucleic acid) that can be used alone or in combination with other identifying data to establish the individual's identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings from which an identifier template such as a faceprint, fingerprint (minutiae template) or voiceprint can be extracted and keystroke patterns or rhythms, gait patterns or rhythms, or other physical patterns, and sleep, health, or exercise that contain identifying information in the data.
|F. Internet or other similar electronic network activity information.
||Browsing history, information regarding a consumer's interaction with a website, or application.
|G. Geolocation data.
|H. Sensory information.
||Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or employment-related information.
||Current or past job history, personnel file information, performance evaluations or similar information.
|J. Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99).
||Education records directly related to a student maintained by an educational agency or institution or by a party acting on behalf of the agency of institution. Education records include grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
|K. Inferences drawn from other personal information.
||Inferences drawn from any of the above categories of information used to create a profile of an individual's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
|L. Sensitive Personal Information
||Social Security number, driver's license number, work authorization information, passport, etc.
Personal information does not include:
- Publicly available information
- De-identified or aggregated consumer information.
- Information excluded, such as:
- medical information covered by the California Confidentiality of Medical Information Act (CMIA) and other applicable state laws or protected health information collected by a covered entity or business associate governed by the privacy, security and breach notification rules in the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and or clinical trial data governed by the Health Information Technology for Economic and Clinical Health Act; and/or
- personal information governed by certain industry specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), applicable state laws and the Driver's Privacy Protection Act of 1994.
Sources from which the personal information listed above is obtained:
- Directly from website visitors. For example, from information provided through form submissions provided by the user to us related to the services provided on this website.
- Indirectly from website visitors. For example, through information we collect through the course of providing services and content.
- Directly and indirectly from activity on this website. For example, personal information is collected from submissions through this website through its Calculator, Forms, Surveys, Online Wills Planner collected from voluntary submissions. This website also collects statistical information such as website usage details automatically. Statistical Information may be "device specific" (meaning it involves information about the hardware and operating system you are using); "location specific" (meaning it involves collecting and processing information specific to your location); "log specific" (meaning it involves information about your Internet Protocol (or IP) address and information about webpage visits such as dates, times, duration and referrals that initiated page visits as well as your registration and establishment of an OWP account); "enewsletter connected" (meaning Subscribing Organization has included your email address in an email distribution list. Subscriber uses to send planned giving emails incorporating content from the website, in which case the website will associate email activity such as opens, click-throughs and opt-outs together with other Statistical Information about your interaction with the website, such as browser history, to create a "user activity profile"); and "cookies" (which involve technologies to collect information when you visit the website).
Use and Disclosure of Personal Information
We may use or disclose the personal information collected for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- For example, if the website hosts a planned gifts calculator, the website will collect Calculator Information. "Calculator Information" is any information you might input when running any of the planned gifts/deduction calculators located on this website. This information could include donor information (such as a name, age, income tax rate); non-descriptive asset information (such as asset value, cost basis, and current return); and information related to your charitable giving or financial planning goals (such as desired trust return or sales proceeds). You provide us with personal information in order for us to prepare a calculator proposal. Running any calculation with a website calculator will require that you input certain Calculator Information. Calculator Information is encrypted as it passes through the Internet. The Calculator does rely on "session cookies" to operate which means the website will only use the information you input into the Calculator during your current session (or visit). Once you end your current session, the website will not save any Calculator Information unless you choose to send a non-encrypted email of the calculator proposal through the website (in the form of a weblink) to yourself and/or other person(s). Subscriber will not have access to any calculation unless you email a calculation weblink to Subscriber. Except for EU-based web visitors, Subscriber will see Form Information and Statistical Information about your page visits to the Calculator and Statistical Information will associate your page visit to your unique user activity profile if your email address is enewsletter connected.
- To provide you with information, products or services that you request from us submitted in any online form contained on this website. This includes information you submit through the "Contact Us" form to contact Subscriber, the form used to "Sign Up" for the website's related enewsletter, or the form used to request an estate planning guide or to create an online wills planner account from Subscriber. Typically, these forms ask for your First Name, Last Name and an Email Address and also provide a Comments section and will be viewable by Subscriber. All Form Information submitted through the website will be viewable by and accessible to Subscriber in the manner selected by Subscriber (such as behind a password-protected online account provided by Crescendo to Subscriber and/or by way of forwarded email to an email account established by Subscriber).
- To facilitate the disclosure and sharing of information with you, Subscriber or others but only in ways consistent with this Privacy Statement and the user's sharing permissions.
- To provide you with email alerts, advertising or marketing and other notices concerning Subscriber, that may be of interest to you.
- For example, if Subscriber sends surveys via email, the website will collect Survey Information. "Survey Information" is any information you might enter by responding to an email inviting you to share opinions and feedback through a survey. Survey forms permit you to select answers to questions, request assistance or explain your reasons for supporting the Subscriber. The Survey form may also permit you to update your contact information. All Survey Information submitted through the website will be viewable by and accessible to Subscriber in the manner selected by Subscriber (such as behind a password-protected online account provided by Crescendo to Subscriber and/or by way of forwarded email to an email account established by Subscriber).
- To improve our website and the user's experience of the website.
- For testing and internal research for technological development.
- To provide analytic services, statistical information and product development to Subscriber.
- For example, "Statistical Information" is basic information collected by the website about how you use the website and access its content, such as which pages you have visited. Statistical Information may be "device specific" (meaning it involves information about the hardware and operating system you are using); "location specific" (meaning it involves collecting and processing information specific to your location); "log specific" (meaning it involves information about your Internet Protocol (or IP) address and information about webpage visits such as dates, times, duration and referrals that initiated page visits as well as your registration and establishment of an OWP account); "enewsletter connected" (meaning Subscribing Organization has included your email address in an email distribution list Subscriber uses to send planned giving emails incorporating content from the website, in which case the website will associate email activity such as opens, click-throughs and opt-outs together with other Statistical Information about your interaction with the website, such as browser history, to create a "user activity profile"); and "cookies" (which involve technologies to collect information when you visit the website). Use of Statistical Information. Statistical Information will be made available to Subscriber behind a password-protected online account provided by Crescendo to Subscriber. Statistical Information may be incorporated into general analytics for use by Subscriber to understand how website visitors utilize the website and, if your email address is enewsletter connected or associated with an OWP account, may be used to combine your website and enewsletter history to compile a user activity profile for use by Subscriber to market major, blended and planned giving information that might be most relevant or of greatest interest to you.
- This website may be enabled with certain services provided to Subscriber by third party enabled service providers, such as Google, Inc., ("Google") including potentially Google Analytics, Google Search, Google Forms or Google Tags (the "Google Services"). Please note, third party enabled features have their own privacy policies, including but not limited to the collection of device-specific information, log information, location information and cookie-related information. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
- As necessary and appropriate to protect against security incidents.
- To verify and maintain the quality and safety of our website and services.
- For example, to improve the website presentation and utilization and for troubleshooting purposes.
- For purposes of aggregating, collecting, studying and reporting website, enewsletter, survey, calculator utilization, experiences and practices that are anonymous with respect to any website visitor.
- In any circumstance where disclosure may be required by law.
- For example, if Crescendo is compelled to disclose information due to a valid law enforcement request or subpoena, disclosure may occur.
Protect Your Personal Information
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Please take care to protect sensitive information and avoid transmitting sensitive information through the website. We do not knowingly collect personal information from children under the age of 13.
Disclosure of Personal Information
Crescendo is hosting the website for Subscriber. All Calculator Information, Form Information and Statistical Information collected by the website belongs to Subscriber and is information accessible to Subscriber, subject to the permissions and limitations of this Privacy Statement.
Subscriber has agreed that any personal information we provide for a business purpose will be kept as Subscriber's sole and exclusive property and not use it for any purpose except performing the contract or as intended within the direct business relationship between the website user and Subscriber. We may disclose your personal information to a third party for a business purpose.
We may disclose the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: Categories of personal information.
Category C: Protected classification characteristics under applicable state or federal law.
Category F: Internet or other similar electronic network activity information.
Category G: Geolocation data.
Category K: Inferences drawn from other personal information.
The personal information collected above for a business purpose may be disclosed to the following categories of third parties:
- Third party enabled service providers, such as Google, including those to whom you authorize us to share your personal information in connection with the products, services or information we provide to you and when required to do so by law or otherwise to protect our legal rights, property, and safety. Please note, third party enabled features have their own privacy policies, including but not limited to the collection of device-specific information, log information, location information and cookie-related information. We do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We do not engage in targeted advertising based on personal information we collect.
Sale of Personal Information
We will not sell personal information collected. We have not sold personal information we collected in the last 12 months. We do not have any actual knowledge that we sell the personal information of minors, including those under 13 years of age.
Consumer Privacy Rights and Choices
Applicable state laws provide consumers with specific rights regarding their personal information. This section describes your rights under applicable state privacy laws and explains how to exercise those rights to access, request deletion or opt out of the sale of your personal information.
Right to Access Your Information
You have the right to request disclosure of certain information about our collection and use of your personal information. In order to disclose the information, you must submit an authenticated consumer request. We will disclose the following information to you:
- The categories of personal information we collected about you.
- The categories of sources we used to collect the personal information about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share your personal information.
- The specific pieces of personal information we collected about you in a portable data format.
- If we sold or disclosed your personal information for a business purpose, we will provide two separate lists disclosing:
- the personal information categories that each category that was sold;
- the categories of third parties who purchased the personal information; and
- the category of personal information purchased by each third party purchaser.
- Note: In the preceding twelve (12) months, we have not sold any personal information we collected.
- Disclosures for a business purpose in the past 12 months:
- the categories of personal information
- the category of third party recipients who received the personal information category; and
- whether personal information of minors under 13 years of age has been obtained.
Right to Portability
When exercising the right to access, we will attempt to provide the data to the extent technically feasible, in a readily usable format.
Right to Correct Inaccurate Information
You have the right to request a correction to your personal information that you find to be inaccurate. In order to correct the information, you must submit an authenticated consumer request.
Once we receive and confirm your correction request, we will use commercially reasonable efforts to correct the inaccurate personal information about you.
Right to Limit Use of Sensitive Personal Information
You have the right to limit the use of sensitive personal information that we collect from you. Once we receive and confirm your authenticated request to limit the use, we will seek to implement the limits on your sensitive personal information from our records.
Right to Request Deletion
You have the right to request that we delete any of your personal information that we collected from you. Once we receive and confirm your authenticated request to delete, we will delete your personal information from our live databases, unless an exception applies.
We may be unable to complete your deletion request if retaining the information is necessary for one or more of the following reasons:
- In order to complete the transaction for which the personal information was collected, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or to prosecute those responsible for such activities.
- To debug our products and services to identify and repair errors that impair existing intended functionality.
- In order to exercise free speech, ensure the right of another consumer to exercise his or her free speech rights, or exercise another right provided for by law.
- To comply with the California Electronic Communications Privacy Act (California Penal Code § 1546 et seq.) and other applicable state privacy laws.
- To engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion is likely to render impossible or seriously impair the achievement of the research, if you previously provided informed consent.
- To enable solely internal uses that are reasonably aligned with the consumer's expectations based on the consumer's relationship with us.
- To comply with a legal obligation.
- To otherwise use the consumer's personal information for internal and lawful uses of that information compatible within the context in which the consumer provided the personal information.
If one of the above exceptions apply, we will respond to your authenticated consumer request with the reason we are unable to delete your personal information.
Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information.
We will not sell personal information collected. We have not sold any personal information we collected in the last 12 months. We do not have any actual knowledge that we sell the personal information of minors, including those under 13 years of age.
Exercising Your Privacy Rights
To exercise your right to access and/or delete your personal information, as described above, please submit an authenticated consumer request to us by providing your first name, last name and email address. You will receive a confirmation code to authenticate your identity via email. You can exercise your rights by either:
Only you or a person (agent) that you authorize to act on your behalf, may make an authenticated consumer request related to your personal information. You may also make an authenticated consumer request on behalf of your minor child.
You may only make an authenticated consumer request free of charge for access to your personal information twice within a 12-month period. Crescendo may charge an amount allowed by applicable law for subsequent requests. The consumer request must provide sufficient information that allows us to reasonably authenticate that you are the person about whom we collected personal information or an authorized representative.
You are not required to create an account in order to make an authenticated consumer request. We will only use personal information provided in an authenticated consumer request to authenticate the consumer's identity or authority to make the request on behalf of a consumer.
If a consumer has an authorized agent exercise their rights, we will require proof that the consumer provided written authorization to the authorized agent to submit the request. We may request that the consumer authenticate their own identity or directly confirm that the consumer provided the authorized agent with permission to submit the request. We will accept a legal Power of Attorney under the applicable Probate Code from your authorized agent. To make a request using an authorized agent use Privacy Rights Contact form
and email [email protected]
to provide the documentation demonstrating the authorized the agent has authority to exercise rights on your behalf.
Response Timing and Format
We will attempt to respond to an authenticated consumer request within 45 days of its receipt. If we require more time to fulfill your request, we will inform you of the reason and extension period in writing. Generally, the applicable state law allows for an extension of 45 days, for a total of 90 days to respond if necessary.
If you have an account with us, we will make our response available in that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. If we are unable to respond to a request, we will explain the reasons we cannot comply with a request. We will provide your personal information in a format that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
If we determine that your request exceeds more than the twice allowed annually or is excessive, repetitive, or manifestly unfounded, we may request a fee in an amount allowed under applicable law to be charged in order to respond to the consumer request. If a fee will be charged, we will notify you how we came to that decision and provide you with a cost estimate before completing your request.
If you would like to appeal any decision, please send us an email [email protected]
, with the subject line "appeal." We will attempt to respond to an appeal of a decision related to a consumer request within 45 days of its receipt. The response will include any actions we have made in response to the appeal and a written explanation of the reasons to support our response. If you have continued concerns related to the appeal, you have the right to contact the attorney general of your state of residence.
We will not discriminate against you for exercising any of your rights under the applicable state privacy laws, including, but not limited to:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
EUROPEAN UNION PRIVACY RIGHTS NOTIFICATION
This specific section of the Privacy Statement only applies to persons defined as a "data subject" by the European Union's ("EU") General Data Protection Regulation ("GDPR"), which went into effect on May 25, 2018. GDPR is designed to protect the privacy rights of EU data subjects. This section of the Privacy Statement also contains information about the rights of a data subject and, if you are a data subject, this section of the Privacy Statement is here to make you aware of your rights.
In order to comply with GDPR, this website will operate differently when it is accessed from an internet protocol ("IP") address which Crescendo believes is based in the EU (an "EU Website Visit"). Specifically:
- Disabled Features. Certain features of this website that are otherwise described in this Privacy Statement will be disabled including: (a) the ability to send a weblink related to any Calculator output; (b) any web forms found on the website designed to allow a website visitor to contact Subscriber; (c) the Online Wills Planner; and (d) data collection and analytics related to an EU Website Visit. Accordingly, the website will not collect Calculator Information (except in the form of a "session cookie" in the event you use one of the Website's online Calculators during your visit), Form Information, OWP Information or Statistical Information about an EU Website Visit, notwithstanding and general terms described above.
Under GDPR, a "data subject" has certain rights, including:
- Right to Notice. A data subject has the right to be notified about how his or her personal data will be stored or used. Consistent with those rights, you are advised that: (a) Crescendo is hosting this website for Subscriber; (b) Crescendo is based in Camarillo, California in the United States; (c) Crescendo's servers are based in the United States; and (d) this website is hosted on Crescendo's servers.
- Right to Manage Data. A data subject has: (a) the right to request a copy, or report, of any personal data that the website or Subscriber has collected about the data subject; (b) the right to correct or rectify any personal data that is incorrect; and (c) the right to "be forgotten" which means the data subject can request to have his or her personal data erased or deleted.
- Right to Object. A data subject has the right to object to and restrict the processing of his or her personal data. This right includes the right to object to processing of personal data for purposes of direct marketing. To exercise this right, any person may use the "unsubscribe" features contained in the footer of any email marketing communication received from Subscriber that relates to this website (such as the email newsletter that incorporates this website's weekly articles).
- Right to Understand Data Retention. A data subject has the right to understand how data related to the use of any website will be used. As noted above, this website does not collect analytical or statistical information related to EU Website Visits (except for "session cookies" but only as previously disclosed). Crescendo regards information about any data subject that is provided by Subscriber to Crescendo ("Subscriber Data") to be the property of Subscriber to the maximum extent permitted by GDPR. Crescendo does not share Subscriber Data with any third party. Crescendo will store Subscriber Data on Crescendo's live database for as long as this website remains active and possibly for a longer period of time, as determined on a case-by-case basis, depending on: (i) the nature of Subscriber Data; (ii) the reason for collection, which is based on Subscriber's or Crescendo's operational needs; and (iii) consistent with written processing instructions that have been provided by Subscriber to Crescendo.
Under GDPR, Subscriber is acting as the data "controller" who is responsible for responding to any requests about any data subject's rights under GDPR. To contact Subscriber, please send an email to [email protected]
Interaction with "Do Not Track" Settings
The following statement is made in compliance with California's Online Privacy Protection Act of 2003 ("OPPA"). If your browser is set to "do not track," collection of any information by the website will follow the procedures outlined in this Privacy Statement. Website functionality may be limited if your browser is set to "do not track."
Updates to Privacy Statement
This Privacy Statement has been created and approved by Crescendo Interactive, Inc. Crescendo reserves the right to amend this Privacy Statement to reflect the current status of Crescendo's services, the operation of Crescendo's servers and technology, and/or to keep current with any legal requirements related to online privacy. If changes are made to this Privacy Statement, then the text of this Privacy Statement will be updated at this URL and the date at the end of the Privacy Statement will change to reflect the date of the most recent revisions. For material changes, you may be notified, as required by state consumer privacy laws. You may submit inquiries about this Privacy Statement to [email protected]
Links to Other Sites
This Privacy Statement applies to this website. This website, and incorporated content, features and programs, are supported by Crescendo Interactive, Inc. and are licensed to Subscriber under the product names of GiftLegacy or GiftLaw. You may encounter links to other websites such as those belonging to Subscriber (including for purposes of making a current (cash) gift via credit card or other online payment system to Subscriber), various federal or state agencies within the United States or other external organizations. Please be aware that Crescendo is not responsible for the information practices or privacy policies related to these external websites or the organizations that host these websites. If you have comments about this website, its content, any associated emails, enewsletters or any calculator hosted on this website, please direct your comments to [email protected]
. Comments concerning the websites of external organizations should be directed to the external organizations named on those websites.
This website is informational and educational in nature. This website is not offering professional legal, tax, accounting, financial or estate planning advice. All persons who use information from this website must seek their own independent and qualified professional advice. For specific advice about the effect of any gift planning concept on your legal, estate planning, tax, accounting or financial situation, please consult a qualified professional advisor.
If you have any questions, comments or concerns about our Privacy Statement, our collection and/or use of your personal information, your choices and rights regarding such use or wish to exercise your rights under applicable state privacy law, please do not hesitate to contact us by:
Effective Date: May 17, 2023