Privacy Policy

Last Updated: November 27, 2023

Social Investments Management Atlas Ltd. ("Company, "we", "our" or "us") designed and operates the Atlas Grants and Impactor Internet platforms and their related services (each, the "Platform") to enable its clients - with respect to Atlas Grants - non-profit organizations, and their employees, to have access to a wide variety of donation and fundraising sources and fundraise more effectively, and with respect to Impactor corporates, philanthropists, impact venture capital funds and family offices and philanthropic organizations - manage and track their donations and donation processes (as applicable), more effectively and accurately. During your interaction with the Platform, we may collect, and you may provide us with, certain personal data, which identifies you or may identify you directly or when associated with other information ("Personal Data"). This privacy policy ("Policy") is intended to describe our privacy practices and the way we treat your Personal Data, to allow you to better understand what is being done with your Personal Data as well as your rights with respect to the Personal Data we collect. We may also collect browsing information and other information from you that does not directly identify you as an individual, but may identify your device, such as information about your browsing activities and information about the devices you use to access the Platform. We may aggregate or de-identify Personal Data we collect in a manner which does not identify any individual ("Aggregate Information"). We reserve the right to use and disclose Aggregate Information in any manner permitted by law except as otherwise provided in this Policy.

BY USING OR ACCESSING THE PLATFORM AND BY PROVIDING US WITH YOUR PERSONAL INFORMATION YOU AGREE TO THIS POLICY. THEREFORE, PLEASE TAKE A MOMENT TO FAMILIARIZE YOURSELF WITH THE POLICY BEFORE USING THE PLATFORM AND BEFORE PROVIDING US YOUR PERSONAL INFORMATION. IF YOU ARE SITUATED IN THE EEA (EUROPEAN ECONOMIC ZONE)/UK/SWITZERLAND OR A RESIDENT OF CALIFORNIA AND OTHER US STATES, PLEASE SEE ALSO SECTION 10  ("EEA (EUROPEAN ECONOMIC ZONE)/UK/SWITZERLAND ADDITIONAL RIGHTS AND NOTICES"), AND SECTION 11  ("CALIFORNIA AND OTHER US STATES PRIVACY RIGHTS NOTICE AT COLLECTION"), AS APPLICABLE, FOR SPECIFIC DISCLOSURES WITH RESPECT TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AND ADDITIONAL RIGHTS YOU MAY HAVE UNDER APPLICABLE LAW.

  1. Personal Data We May Collect and Process

    When subscribing to the Platform and when using or accessing the Platform, regardless of whether you have subscribed to it or the entity you work for or represent has subscribed to it, you may be asked to provide certain information and we may collect it, analyze and process it, including Personal Data, such as:

    1. Your first and last name, email address, phone number and address.
    2. Your profile data such as your username and password, photograph or picture, links to your profiles on social networks, interests, preferences, and any other information that you add to your account profile.
    3. The details of the non-profit organization you are affiliated with.
    4. Your preferences for being contacted by us.
    5. Payment data and billing information.
    6. Any other information that you choose to provide, and other information described in this Policy.

    In addition, we may also collect, analyze, and process information from you automatically relating to the use and performance of various aspects of the Platform and related technologies.Examples of such information include:

    1. The town / city, county / state and country from which you access the Platform.
    2. The date and time of your visit.
    3. Referring webpages through which you access the Platform.
    4. Type of device you use to access the Platform and its technical and related additional information, including the type of browser, the Internet service provider, IP address, its brand and model, operating system, memory size, screen resolution, system performance, network type and unique identifiers (including such that are used for advertisement purposes). 
    5. Your usage, browsing habits and similar data including the pages you use, navigate to or view on the Platform and the duration of interaction, the number and type of links you click within the Platform; alerts and working plans you set for yourself or for co - users in the Platform, and certain searches and queries that you conduct in the Platform as well as other information you store in the Platform. 
    6. If you choose to synchronize the Platform with a Google Calendar or any external resources and allow it to get access to such resources, this includes information stored in this calendar and resources. 
  2. Purposes of Collection, Analysis and Processing of Personal Data

    The personal data collected and processed by the us and on our behalf will serve it for these purposes:

    1. Operation of the Platform and provision of optimal and personalized information and services on the Platform, as well as improvement of the user experience in general, including by research and development to establish improved and new features and services and performance optimization for the devices you use to access the Platform.
    2. Protection of the Platform and its content from inappropriate use, including identification and authentication of active users and enabling or disabling access to the Platform and prevention, identification, investigation and deterring fraudulent, harmful, unauthorized, unethical or illegal activity.
    3. Establishing and maintaining your user profile on the Platform and understanding your needs and interest to allow personalization of your experience with the Platform and our communication with you.
    4. Maintaining contact with you for e - mail alerts, newsletters, surveys, direct marketing and sales offers, and customer support, via any communication channel such as e - mail, SMS, phone calls and via the Platform.You hereby consent to receiving such communications.
    5. Auditing our internal processes with respect to the Platform, customer support, billing, subscription, the communication channels used to contact you and related processes.
    6. Compliance with the applicable law, legal contractual obligations, lawful inquiries, court orders and orders of competent authorities.
    7. For our lawful business purposes, including research and development, analysis and improvement of the Platform and promotion of our business, we may create and use de - identified and / or anonymized Aggregated Data, by removing from the Personal Data information that is personally identifiable("De - Identified Data").We may use De - Identified Data ourselves and share it with our third - party partners for the purposes mentioned above.
    8. For any other appropriate purpose, with your consent, which we make ask for separately in some cases.
  3. Cookies and Similar Technologies

    The Platform itself does not use "cookies" (text files placed on your computer) and similar technologies, however it may use Google Analytics - a web analytics service provided by Google, Inc. ("Google"), which uses "cookies", and through which Google will collect certain information to be used according to Google’s privacy practices, to which your consent is hereby given – please review them here: https://policies.google.com/privacy. NOTE: IF YOU USE ANY MEANS TO BLOCK OR OPT - OUT FROM GOOGLE ANALYTICS, THEN YOU WILL NOT BE ABLE TO USE THE PLATFORM AND YOUR ACCESS TO THE PLATFORM WILL BE DENIED.

  4. Google API Services User Data

    In addition, the Platform uses Google API Services including Google Sign - In, as part the authentication and access authorization, to allow you to sign -in to the Platform using your active Google account including automatic sign-in if you are already logged in to your Google account.Usage of Google Sign - In is also subject to Google’s privacy practices, and by using this service you consent to their terms(see above). The Platform’s use and transfer to any other app or platform of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

  5. Disclosure to Additional Third Parties

    In addition to the terms and conditions of Section 3 and 4 above, we may also share your Personal Data with the following third parties as set - forth in this Policy or as otherwise described in applicable privacy notices at the time of collection:

    1. Any payment card and bank account details or other billing information you provide to purchase a subscription to the Platform or make a purchase of related services is collected and may be processed directly by our payment processors, such as Stripe, which may use the payment data you provide in accordance with its privacy policy – if applicable pleaser review it here: https://stripe.com/privacy.
    2. Third patties in compliance with the terms of Section ‎2(‎f) above.
    3. Consultants such as lawyers, auditors, and financial consultants, if such sharing is required and to the extent required, while rendering their professional services.
    4. Service providers that render services to us or on behalf of us or assist us with the operation of the Platform and related services, including hosting, repository and email services, online chat, Platform analytics, marketing and user research services.
    5. Prospects and parties(including their consultants) to prospective and actual business and financial transaction(s) to which the Company is may be a party, such as raising capital(debt or equity), initial public offering, merger of the Company with another entity or the acquisition of the Company’s shares or its assets and similar transactions.The same shall apply also in the event of insolvency or receivership or similar proceedings, in which the Personal Data is deemed an asset of the Company and is transferred to a third - party as such.
    6. Other users of the Platform insofar as they get access to the profile of other users and their contact information.
  6. Personal Data Retention

    We will retain Personal Data for a duration that is reasonably necessary to uphold the services of the Platform, to enforce contractual agreements and comply with other legal and accounting obligations.This duration also allows for the resolution of and for execution of other purposes described in this Policy, or as otherwise mandated or permitted by law, unless specifically authorized for extended retention.Please note that even if we delete some or all your Personal Data, we may continue to retain and use De - Identified Data previously created.

  7. Children

    The Platform is neither meant for nor designed for utilization by individuals under the age of 18. Should you, as a parent or legal guardian, suspect that we have gathered Personal Data from a minor in a manner not in accordance with the law, we kindly request that you contact us. If we discover that Personal Data has been collected from a minor via the Platform without obtaining the necessary consent from the minor’s parent or legal guardian as mandated by law, we will take appropriate measures to erase this Personal Data in compliance with relevant legal stipulations.

  8. Updates and Changes to this Policy

    We reserve the right, at our discretion, to change, modify, add or remove portions from this Policy at any time by posting such changes here.We will notify you of any material changes by updating the date of this Policy and posting it here and by other appropriate means, such as a notification message for a certain period of time on the Platform or an e - mail message.Your continued use of the Platform following the posting of any changes to this Policy indicates your acceptance of such changes.IF YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU ARE NOT AUTHORIZED TO ACCESS OR OTHERWISE USE THE PLATFORM.

  9. How to Contact Us

    For any inquiry related to this Policy and your rights please contact us at: Info@atlas-grants.com

  10. EEA(European Economic Zone) / UK / Switzerland Additional Rights and Notices

      We rely on the following legal basis to process your Personal Data:

      • Your consent to the processing(as such term is defined in the GDPR, as defined below) of your Personal Data as set forth in this Policy, which is granted by your usage of the Platform.
      • It may be necessary for us to process your Personal Data for the performance and fulfillment of the contract between us and to provide you with the services of and related to usage of the Platform.
      • We may process your Personal Data where it is necessary for our legitimate interests(or those of a third party) and your interest and fundamental rights do not override those interests.
      • We may process Personal Data if we find it necessary to protect your vital interests or those of another natural person.
      • We may also process Personal Data if it is necessary for compliance with legal obligations to which we are subject to.

      If you are located in the European Economic Zone, United Kingdom or Switzerland with rights under the  EU General Data Protection Regulation("GDPR") or comparable national laws, you have the right you have the right to obtain access to the personal data held by us about you and to request its rectification or erasure, or restriction of processing or, where applicable, the right to object to processing or the right to data portability. Where the processing is based on your consent or explicit consent, you also have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

      HOWEVER, REVOKING YOUR CONSENT, OBJECTION TO PROCESSING OR A REQUEST FOR ERASURE SHALL REVOKE YOUR RIGHT TO USE THE PLATFORM SINCE WE WILL NOT BE ABLE TO PROVIDE YOU WITH THE SERVICES OF THE PLATFORM.

      We have put in place reasonable physical, electronic and managerial procedures to safeguard the Personal Data we collect; however, due to the inherent open nature of the Internet, we cannot guarantee that all information will be free from unauthorized access by third parties, such as hackers, and your use of the Platform demonstrates your assumption of this risk.Please note that we will not be liable for disclosures of your Personal Data due to errors or unauthorized acts of third parties.

      The Personal Data you provide us with or such that we collect, will be retained as set forth in Section 6 above – please refer to that Section for more information. 

      We use AWS(Amazon Web Services) servers that might be maintained in the United States of America("USA").By using the Platform, you freely and specifically give us your consent to export and store your Personal Data in the USA.You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA. We may transfer Personal Data from the European Economic Area(EEA), United Kingdom and Switzerland to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection.Personal Data collected in the EEA will be transferred in compliance with the requirements of the GDPR.

  11. California and Other US States Privacy Rights Notice at Collection

    Except as otherwise provided, this section applies to residents of California and their rights under the California Consumer Privacy Act of 2018("CCPA") as well as residents of other states, to the extent that such states have applicable privacy laws, granting the rights set forth in this section.If a different term is used in the applicable privacy law, then Personal Data shall have the meaning given to "personal information" or PII or similar term used in the applicable privacy law of the state in which you reside.

    Please note that not all rights listed below may be afforded to all users of the Platform and that if you are not a resident of the relevant states, you may not be able to exercise these rights.In addition, we may not be able to process your request unless you provide us with sufficient details to allow us to confirm your identity or allow us to process and respond to your request.

    1. Please note that while you may have some or all of the following rights, these rights may be limited in some cases and to the extent permitted by law we may decline your request: you have the right to know about the Personal Data that we have collected in the 12 - month period proceeding your request and how we have used it, the right to delete Personal Data(exceptions apply), the right to opt - out of the sale or sharing of your Personal Data, the right to correct inaccurate Personal Data, the right to limit the use and disclosure of sensitive Personal Data and the right for non - discrimination for exercising your rights under the CCPA or similar privacy law, if so granted under such law. HOWEVER, REVOKING YOUR CONSENT, A REQUEST FOR DELETION OR OTHER REQUEST AS APPLICABLE, SHALL REVOKE YOUR RIGHT TO USE THE PLATFORM SINCE WE WILL NOT BE ABLE TO PROVIDE YOU WITH THE SERVICES OF THE PLATFORM. We would like to clarify that we do NOT "sell" your Personal Data to third - parties and therefore there is no need to opt - out.However, if you would still like to make such a request, as well as to make any other requests regarding your rights, you may do so by contacting us.

    2. We reserve the right to confirm your residency to process your requests and will need to confirm your identity to process your requests to exercise your rights.As a part of this process, government identification may be required. Under the CCPA only you, a person on you authorize to act on your behalf or a business entity you authorize to act on your behalf provided such entity is registered with the California Secretary of State that(an "Authorized Agent"), may make the requests set forth above, or with respect to other State privacy law, insofar as appointing an agent on your behalf is permitted. The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the Personal Data an authorized representative of that person, which is authorized to make the specific request. To designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government - issued identification, and the authorized agent’s valid government issued identification. Note that we cannot process your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to it.

    3. We do not share your Personal Data in a manner that constitutes a "sale," as defined by the CCPA and have not sold or shared Personal Data in the preceding 12 months.We do not have actual knowledge that we have sold or shared the Personal Data of California residents who are under 16 years of age.The

    4. The Personal Data you provide us with or such that we collect, will be retained as set forth in Section 6 above – please refer to that Section for more information.

    5. We do not attempt to reidentify deidentified information derived from Personal Data, except for the purpose of testing whether our deidentification processes comply with applicable law.

    6. If you are a resident of Virginia, then please note that under the  Virgina Consumer Data Protection Act("CDPA"), you can ask to appeal any denial of your request in the same manner through which you may submit a request.We will reply with 60 days of receipt of the appeal and act in accordance with CPDA §59.1 - 577(C).

    7. If you are a Nevada resident, you have certain rights under  2019 Nevada Revised Statues Chapter 603A, including the right to request that we do not sell("Sale" as defined under NRS603A.333) certain Personal Data that we have collected, or may collect, from you. We would like to clarify that we do NOT "sell" your Personal Daat as defined by NRS603A, however, if you would still like to make such a request you may do so by contacting us.