Legal

    Privacy Policy

    Effective Date: June 1, 2026Last Updated: June 1, 2026

    Givelayer Technologies Inc. is committed to protecting the privacy of donors, charities, and visitors to our platform. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you use the Givelayer Service.

    01

    Our Privacy Principles

    Givelayer is built on five privacy commitments:

    1. 1.Minimal collection. We collect only the data necessary to provide the Service.
    2. 2.No data sales. We never sell donor or charity information to third parties.
    3. 3.Charity ownership. Donor data belongs to the receiving charity, not to Givelayer.
    4. 4.Transparency. We tell you what we collect, why, and who has access.
    5. 5.Control. Donors can request access, correction, or deletion of their data at any time.
    02

    Roles and Responsibilities

    2.1 Givelayer as Data Processor

    When charities use our Service to collect donations, Givelayer acts as a data processor on behalf of the charity (the data controller). This means:

    • The receiving charity determines how donor data is used and retained;
    • Givelayer processes donor data only as instructed by the charity and as required to provide the Service;
    • Donors should contact the receiving charity for questions about how their data is used by that charity.

    2.2 Givelayer as Data Controller

    When Givelayer collects information directly from website visitors, charity administrators, or job applicants, Givelayer acts as a data controller for that information.

    03

    Information We Collect

    3.1 Information from Donors

    When a donor contributes through the Service, we collect:

    • Identity information: Full name (required for tax receipts in the United States)
    • Contact information: Email address (required for digital receipts and communication)
    • Mailing address: Required for charitable receipts under IRS Publication 1771
    • Donation details: Amount, date, currency, recipient charity, optional tip amount
    • Payment information: Processed directly by Stripe; Givelayer does not receive or store credit card numbers, CVV codes, or full bank account details
    • Communications: Messages, refund requests, or inquiries sent to support@givelayer.com or to the receiving charity through the Service
    • Optional information: Donor-provided messages, dedications, or anonymity preferences

    3.2 Information from Charities

    When a charity registers for the Service, we collect:

    • Charity identification: Legal name, operating name, registration number (IRS EIN), incorporation date, registered office address
    • Authorized representative information: Name, email, phone, role, government-issued identification (collected by Stripe for KYC)
    • Banking information: Collected and stored by Stripe; Givelayer does not store full bank account numbers
    • Account activity: Login times, IP addresses, dashboard usage, campaigns created, content uploaded
    • Communications: Messages sent to Givelayer support or privacy teams

    3.3 Information from Website Visitors

    When you visit givelayer.com or gvy.to without making a donation or creating an account, we may collect:

    • Technical information: IP address, browser type, device type, operating system, referring URL, pages visited, time on site
    • Cookies and similar technologies: See Section 8 (Cookies and Tracking)
    • Form submissions: Name and email if you join our waitlist or contact us

    3.4 Information We Do Not Collect

    Givelayer does not collect:

    • Credit card numbers, CVV codes, or full bank account numbers (these are handled by Stripe)
    • Social Security Numbers (US) from donors
    • Health information, biometric information, or other special categories of personal data unless voluntarily provided
    • Information from children under 18; the Service is not directed at minors
    04

    How We Use Information

    4.1 To Provide the Service

    We use information to:

    • Process donations and route funds to charities through Stripe Connect
    • Generate receipts on behalf of charities (charity is the legal issuer)
    • Send transactional emails (donation confirmations, receipts, refund notifications) via Resend
    • Display donation history to donors and charity administrators
    • Power the analytics dashboard for charity insights
    • Enable thank-you video features and donor communications
    • Generate QR codes, embed buttons, and flyers for charity campaigns

    4.2 To Operate Our Business

    We use information to:

    • Verify charity registration through IRS databases
    • Verify identity and beneficial ownership through Stripe KYC
    • Detect and prevent fraud, money laundering, and abuse
    • Comply with legal obligations including FINTRAC (Canada) and FinCEN (US) reporting
    • Respond to support inquiries and resolve disputes
    • Improve the Service through aggregated analytics
    • Communicate platform updates, policy changes, and account notifications

    4.3 To Communicate

    We use contact information to send:

    • Transactional emails: Required for the Service (receipts, payment confirmations, account changes)
    • Service announcements: Important updates affecting your account or the Service
    • Marketing communications: Only with your consent and only when legally permitted

    You can opt out of marketing communications at any time using the unsubscribe link in any marketing email or by contacting privacy@givelayer.com.

    4.4 Legal Basis for Processing (GDPR and PIPEDA)

    We process personal information based on:

    • Contract performance: To provide the Service to charities and donors
    • Legal obligation: To comply with tax, AML, and other regulatory requirements
    • Legitimate interest: To improve the Service, prevent fraud, and operate our business
    • Consent: For marketing communications and optional features
    05

    How We Share Information

    5.1 With Charities

    When a donor contributes to a charity through the Service, the donor's name, email, mailing address, donation amount, and any donor-provided message are shared with the receiving charity. The charity uses this information to issue receipts, acknowledge donations, and (where the donor has consented) communicate with donors about future campaigns.

    Donor data shared with charities is owned by the charity, not by Givelayer.

    5.2 With Service Providers

    We share information with third parties who help us operate the Service:

    • Stripe: Payment processing, KYC verification, fraud detection. Stripe's privacy practices are governed by Stripe's Privacy Policy.
    • Cloudflare: Content delivery, DDoS protection, DNS. Cloudflare's privacy practices are governed by Cloudflare's Privacy Policy.
    • Supabase: Database hosting, authentication, file storage. Supabase's privacy practices are governed by Supabase's Privacy Policy.
    • Resend: Transactional email delivery. Resend's privacy practices are governed by Resend's Privacy Policy.
    • ConvertKit (Kit): Marketing email and waitlist management (only for users who opt in). Privacy practices governed by Kit's Privacy Policy.

    These providers are contractually bound to protect personal information and use it only to provide services to Givelayer.

    5.3 With Legal and Regulatory Authorities

    We may disclose information when required by law, including:

    • Reports to FINTRAC (Canada) for suspicious transactions or transactions exceeding regulatory thresholds
    • Reports to FinCEN (United States) for suspicious activity
    • Compliance with subpoenas, court orders, or other legal process
    • Cooperation with law enforcement investigations
    • Disclosure to tax authorities when legally required
    • Compliance with sanctions screening obligations

    5.4 In Business Transactions

    If Givelayer is involved in a merger, acquisition, financing, or sale of assets, donor and charity information may be transferred as part of the transaction. We will notify affected users and ensure that the receiving party is bound by privacy commitments at least as protective as this Policy.

    5.5 What We Do Not Do

    Givelayer does not:

    • Sell donor or charity information to advertisers, data brokers, or third parties
    • Use donor information to target advertising on third-party platforms
    • Share donor information across charities (each charity receives only its own donor data)
    • Disclose donor information without legal basis or donor consent
    06

    International Data Transfers

    Givelayer's service providers may process data in Canada, the United States, the European Union, and other jurisdictions. By using the Service, you consent to such cross-border processing.

    For Canadian users, we comply with PIPEDA's accountability requirements when transferring data outside Canada. For users in the European Economic Area, we rely on Standard Contractual Clauses or equivalent safeguards for transfers outside the EEA.

    07

    Data Retention

    7.1 Donation Records

    Donation records (including donor name, address, amount, date, and receipt details) are retained for a minimum of 7 years following the donation date to comply with:

    • IRS record-keeping requirements
    • Internal Revenue Service (IRS) record-keeping requirements
    • Other applicable tax and regulatory frameworks

    7.2 Account Closure

    If a charity closes its Givelayer account, donor records associated with that charity are retained for 7 years post-account-closure in compliance with regulatory requirements, then permanently deleted.

    7.3 Marketing and Analytics Data

    Marketing communication preferences and aggregated analytics data are retained until you opt out or request deletion, whichever is sooner, subject to legitimate business needs.

    7.4 Other Data

    Other personal information is retained only as long as necessary for the purposes described in this Policy or as required by law.

    08

    Cookies and Tracking Technologies

    8.1 What We Use

    Givelayer uses cookies and similar technologies (including local storage, session storage, and tracking pixels) for:

    • Essential functions: Authentication, security, donation processing
    • Analytics: Understanding how visitors use the Service (aggregated, non-identifying where possible)
    • Preferences: Remembering language, theme, and accessibility settings

    For simplicity, this Policy refers to all of these collectively as "cookies."

    8.2 Types of Cookies We Use

    Strictly Necessary Cookies (required for the Service to function)

    • Authentication cookies that keep you logged in to your charity dashboard
    • Session cookies that maintain your donation flow state
    • Security cookies that protect against cross-site request forgery (CSRF)
    • Cookies set by Stripe to process payments securely

    Functional Cookies (remember your preferences)

    • Language preferences (English/French)
    • Theme preferences (light/dark mode)
    • Accessibility settings
    • Recently viewed campaigns

    Analytics Cookies (help us improve the Service)

    • Page views, time on site, bounce rates
    • Donation conversion rates
    • Feature usage patterns
    • Error tracking

    We use analytics cookies in an aggregated, non-identifying form where possible.

    8.3 Third-Party Cookies

    Some cookies are set by third-party services we use to operate the Service:

    We do not use cookies for:

    • Behavioral advertising, we do not engage in ad targeting
    • Cross-site tracking, we do not track users across other websites
    • Selling data to advertisers

    8.4 Managing Cookies

    Most browsers allow you to:

    • View cookies stored on your device
    • Delete cookies
    • Block cookies from specific websites
    • Block all cookies (this may break functionality)

    Instructions for major browsers:

    8.5 Do Not Track

    Givelayer does not currently respond to "Do Not Track" browser signals because no industry standard has been established for how to interpret them. We will update this Policy if a recognized standard emerges.

    8.6 Opting Out

    You can opt out of non-essential cookies by:

    • Adjusting your browser settings to block cookies
    • Using your browser's private/incognito mode
    • Contacting privacy@givelayer.com to request opt-out from analytics

    Note: Opting out of strictly necessary cookies may prevent the Service from functioning properly.

    09

    Your Privacy Rights

    9.1 Rights Under PIPEDA (Canada)

    Canadian users have the right to:

    • Access their personal information
    • Correct inaccurate or incomplete information
    • Withdraw consent (subject to legal and contractual restrictions)
    • File a complaint with the Office of the Privacy Commissioner of Canada

    9.2 Rights Under State Privacy Laws (United States)

    Residents of California, Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws have the right to:

    • Know what personal information is collected and how it is used
    • Access copies of their personal information
    • Request deletion of personal information (subject to legal exceptions)
    • Opt out of the sale or sharing of personal information (Givelayer does not sell personal information)
    • Opt out of targeted advertising (Givelayer does not engage in targeted advertising)
    • Non-discrimination for exercising privacy rights

    9.3 Rights Under GDPR (European Economic Area, UK)

    Users in the EEA and UK have the right to:

    • Access, rectify, or erase personal data
    • Restrict or object to processing
    • Data portability
    • Withdraw consent
    • Lodge a complaint with a supervisory authority

    9.4 How to Exercise Your Rights

    To exercise privacy rights, contact:

    • Receiving charity (for donor data): Use the contact information on your receipt or campaign page
    • Givelayer (for visitor or charity admin data): Email privacy@givelayer.com

    We respond to verified requests within 30 days for PIPEDA and GDPR, or as required by applicable state law (typically 45 days under US state laws, with possible extension).

    We may need to verify your identity before fulfilling certain requests. Some requests may be denied or limited due to legal retention obligations (e.g., 7-year donation records under IRS rules).

    10

    Security

    Givelayer implements technical and organizational safeguards to protect personal information:

    • Encryption in transit: TLS 1.3 for all data transmitted between donors, charities, and Givelayer
    • Encryption at rest: AES-256 encryption for stored data
    • Access controls: Role-based access with row-level security in our database
    • Authentication: Multi-factor authentication required for charity administrator accounts
    • Infrastructure security: SOC 2-compliant infrastructure providers (Supabase, Cloudflare, Stripe)
    • Code security: Code review, dependency scanning, and infrastructure hardening
    • Payment security: All payment data handled exclusively by Stripe (PCI-DSS Level 1 certified)

    No system is perfectly secure. While we work to protect personal information, we cannot guarantee absolute security. In the event of a data breach affecting personal information, we will notify affected users and applicable regulators as required by law.

    For security concerns or to report a vulnerability, contact security@givelayer.com.

    11

    Children's Privacy

    The Service is not directed at children under 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected information from a child under 18, we will delete it.

    If you believe a child has provided information to Givelayer, contact privacy@givelayer.com.

    13

    Changes to This Policy

    We may update this Privacy Policy from time to time. Material changes will be communicated by:

    • Posting the updated Policy on the Service with a new effective date
    • Sending email notice to charity administrators
    • Displaying a notice on the Service for at least 30 days

    Continued use of the Service after the effective date constitutes acceptance of the updated Policy.

    14

    Contact Us

    For privacy questions, requests, or complaints, contact:

    Givelayer Technologies Inc.

    Privacy Officer

    324 8 Ave SW, 12th Floor

    Calgary, Alberta, T2P 2Z2, Canada

    Email: privacy@givelayer.com

    General support: support@givelayer.com

    For unresolved complaints in Canada, you may contact the Office of the Privacy Commissioner of Canada:

    • Website: priv.gc.ca
    • Phone: 1-800-282-1376

    For unresolved complaints in the United States, you may contact your state attorney general or the Federal Trade Commission.

    By using the Givelayer Service, you acknowledge that you have read and understood this Privacy Policy.

    Questions about your privacy?

    Our Privacy Officer is here to answer any questions or fulfill data requests.

    Email privacy@givelayer.com