1. Introduction
At Founders Pledge (“we”, “us”, “our”), we value the protection and management of your personal information. As a registered charity in England and Wales (charity number 1162201) and a charitable company limited by guarantee incorporated and registered in England and Wales (company number 08565148), we take your privacy seriously and follow strict data protection standards. We want you to feel comfortable and confident using our Services, and our commitment to your privacy is reflected in this Privacy Notice. It outlines how we collect, process, and disclose personal data when you engage with our Website, our donor-advised fund services, our charitable advisory services, and other products and services falling under this Privacy Notice (referred to collectively as the “Services”).
This Privacy Notice covers the data practices of Founders Pledge Ltd and its affiliated entities, including Founders Pledge Inc. and Founders Pledge gGmbH (collectively the “Founders Pledge Group”). It explains how we handle the personal data we collect through your use of our Services, as well as your interactions with us on social media or any other dealings you may have with us.
Founders Pledge Ltd is the data controller responsible for the personal data covered by this Privacy Notice, regardless of where you are based. Where personal data is processed by Founders Pledge Inc. or Founders Pledge gGmbH, those entities do so in accordance with this Privacy Notice and under appropriate data sharing arrangements with Founders Pledge Ltd.
We take our role as custodians of your personal information seriously and strive to fulfill our data protection obligations. If you have any questions or concerns about how we handle your personal data, please don’t hesitate to reach out to us. You can find our contact information in Section 12 of this Privacy Notice.
To ensure that we comply with all applicable privacy regulations, we have designated a Data Protection Officer who assists us in upholding the highest standards of privacy and data security.
Data Protection Officer: Legal Nodes Ltd (Company number 11668206) Address: Office 2, Bennet’s House, 21 Leyton Road, Harpenden, England, AL5 2HU Contact person’s details: dpo.founderspledge@legalnodes.com
2. Information we collect and receive about you
At Founders Pledge, we collect and receive information in different ways through operating our Services and Website, and through other interactions with us. The main categories of personal data we collect and receive includes:
- Contact Information. For example, names, personal and/or work email addresses, home and/or work addresses, phone numbers.
- Identification Information. For example, passport number, driving license details, or national identity card information, used solely for verification purposes.
- Company Information. For example, company name, company location, job title.
- Financial Information. For example, pledge commitment, value of charitable gifts, source of funds, tax residency.
- Charitable Giving Information. For example, cause area interests, previous charitable giving experience.
- Cookies and Analytics. For example, IP location, the browser and device used to access our Website.
We may collect additional information with your consent. This information may include, but is not limited to, family information, religious or philosophical beliefs, health data (e.g. dietary requirements or requests for reasonable adjustments), and other financial information, such as estimates of net wealth.
3. Purposes for which we use your data
At Founders Pledge, we will only use your personal data if we have a lawful basis.
The specific purposes for which we process your personal data, and the lawful basis applicable to each, are set out in detail in Appendix 1.
By way of overview, the most common lawful bases we rely on are:
- Consent: In some cases, we may process your personal data only if we obtain your prior consent.
- Performance of a contract: We will require your personal data to offer you the services in accordance with the contract terms between you and us.
- Compliance with a legal obligation: Due to the nature of the services we provide, the laws applicable to our activities require us to collect and store certain data about you.
- Legitimate interests: Sometimes, we rely on our legitimate interests to process your data. The specific legitimate interests we rely on for each category of data subject are set out in Appendix 1. We will only do so unless these interests are overridden by your interests or fundamental rights and freedoms.
- Explicit consent: In some cases, such as when collecting special categories of data (e.g. data concerning health, philosophical and religious beliefs), we may process your data only if we obtain your explicit consent to such processing pursuant to Article 9.1 and 9.2(a) GDPR/UK GDPR.
If you do not provide the personal data required to access our Services, or if we are legally obligated to process personal data, you may not be able to use our Services. We need this data to fulfill our obligations and comply with the law. So, providing certain personal data is necessary to use our Services.
5. Sources of Personal Data
We obtain most of your personal data directly from you, either when you register to use our Services or communicate with us. In some cases, we may also receive personal data about you from third parties and publicly accessible sources, such as social media platforms (e.g., LinkedIn), introductions made by existing members, public databases (e.g., Crunchbase), and analytics providers, among others.
Additionally, we may collect usage data automatically through the use of cookies and similar technologies when you use our Services. This helps us understand how you interact with our Services and improve your overall experience.
We combine the data received directly from you with information obtained from third parties and publicly accessible sources, as well as automatically collected usage data, to provide you with a comprehensive and optimized user experience.
We may also receive personal data about you from third-party organisations, such as companies or employers that have partnered with us to make our services available to their employees or members. Where we receive personal data about you in this way, we will use it only for the purposes described in this Privacy Notice and in Appendix 1, and we will provide you with this Privacy Notice at or before the point at which we first contact you.
6. Protecting your Personal Data
We take the security and protection of your personal data very seriously. We use reasonable and appropriate technical and organizational measures to ensure the safety of your information. Our measures are designed to prevent loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction of personal data.
We implement robust security protocols and stay up-to-date with industry best practices to maintain the confidentiality, integrity, and availability of the personal data you entrust to us.
We continuously review and enhance our security measures to address emerging threats and maintain a high level of data protection. Your information is important to us, and we strive to safeguard it to the best of our ability.
7. Retaining your Personal Data
We will keep your personal data only as long as necessary to fulfill the specific purpose for which we collected it. This means we will keep it for as long as we need to meet any legal, accounting, or reporting requirements, or to serve our legitimate interests. For example, we will keep most of your data for up to 7 years after our business relationship with you ends. However, we may need to keep certain information, such as tax residency details, for a longer period to comply with our legal obligations.
In some cases, authorities may require us to keep personal data for an extended period, such as in an ongoing investigation.
Our data retention practices comply with applicable laws and regulations and we ensure the appropriate protection and security of your personal data.
8. Your Rights
You have specific rights regarding the collection and processing of your personal data, which you can exercise, subject to applicable exceptions. These rights include:
- Confirmation and Access: You can ask us to confirm whether we process your personal data and to access the personal data we have processed.
- Correction: You can request correction of inaccuracies in your personal data held by us.
- Withdrawal of Consent: You can withdraw your consent and request the removal of your personal data that we collected based on your consent. This includes opting out from receiving marketing communications from us.
- Restriction of Processing: You can request the restriction of processing of your personal data, such as when you contest the accuracy of the data, for a period allowing us to verify its accuracy.
- Data Portability: If technically feasible and not infringing on the rights and freedoms of others, you can have your personal data transmitted directly from one data controller to another.
- Erasure: Under certain circumstances, you can request the erasure of your personal data. Please refer to the “How long do we keep your personal data” section for more information on our data retention obligations.
- Objection: You can object to the processing of your personal data when such processing is carried out for the performance of tasks in the public interest or the exercise of official authority vested in us.
To exercise any of the above rights, please contact us at info@founderspledge.com, providing your name and specifying the right you wish to exercise.
You can also lodge a complaint with us or the ICO, the supervisory authority for data protection issues in the UK. If you are based outside of the UK, you can find the relevant supervisory authority for your jurisdiction here.
We aim to provide you with information on the actions taken in response to your request regarding your rights within one month of receiving the request. If the request is complex or if there is a large number of requests being processed, the response time may be extended by two additional months. In such cases, we will inform you of the extension and provide the reasons for the delay within one month of receiving the request.
9. Sharing your Personal Data
We will share your data with the following third parties:
- Legal entities in the Founders Pledge Group;
- Professional advisors such as lawyers, accountants, banks, auditors, or insurers;
- Law enforcement, government, and regulators, or other third parties as required by applicable law or regulation (including but not limited to the Charity Commission for England and Wales, the ICO and HMRC);
- Suppliers or subcontractors involved in the performance of any contract we have with you;
- If you are a Member, with Authorised Advisors of a DAF of your choice and according to the level of access you have decided to grant them, namely your giving history and transactions/DAF balance; and/or
- Where you have joined Founders Pledge through a corporate partnership arrangement, with the relevant corporate partner for the purpose of administering any match funding or employee benefits arrangement under that partnership.
In addition,except for those employees participating under a corporate partnership scheme, we may share the name and email addresses of business professionals with Pledge Ventures Limited (company number 14306490, registered address Salisbury House (Unit 252) 29 Finsbury Circus, London, England, EC2M 5QQ) based on our legitimate interests of fostering our membership community. Pledge Ventures may then contact you to inquire about your interest in their products and services. To opt out of having your data shared with Pledge Ventures Limited, please contact our team at info@founderspledge.com.
If Members consent, we will also share your contact information with other Members (current and prospective) to facilitate networking and community connection.
Please note that we only share your personal information with third parties as outlined in this Privacy Notice.
If we transfer your personal data to service providers or other recipients located outside the UK or the European Economic Area (EEA), we will take appropriate measures to safeguard your personal data. For transfers from the UK by Founders Pledge Ltd, this includes implementing International Data Transfer Agreements (IDTAs) issued by the Information Commissioner’s Office, or — where the recipient is certified under the UK-US Data Bridge — relying on that framework as the transfer mechanism. For transfers made by our German entity, Founders Pledge gGmbH, we use Standard Contractual Clauses approved by the European Commission. If you would like more information about the specific mechanism used for any particular transfer, please contact us.
We may also disclose your personal data in the following circumstances:
- To affiliates and subsidiaries within the Founders Pledge Group, including parent and ultimate holding companies, affiliates, subsidiaries, business units, and future legal entities acquired by the Founders Pledge Group;
- In the event of a merger, acquisition, sale, change of control, or similar transaction or proceeding;
- To establish, exercise, or defend legal claims; and/or
- With your consent to the disclosure.
10. Privacy Notice updates
We may need to update this Privacy Notice from time to time. If we make significant changes to how we collect, process, or use your personal information, we will let you know by posting the updated Privacy Notice on our Website or through other appropriate communication methods.
11. Contact Us
If you have any questions about this Privacy Notice or our privacy practices, or if you want to exercise any of your rights, please contact us at info@founderspledge.com. You can also contact our Data Protection Officer at dpo.founderspledge@legalnodes.com.
If you live in the UK, you have the right to file a complaint with the ICO (Information Commissioner’s Office). For those residing in the EEA, you have the right to make a complaint to the data protection supervisory authority in your usual residence, workplace, or the place where the alleged violation occurred.
Appendix 1. Personal Data Table
| Data Subject | Purpose | Personal Data | Lawful Bases for Processing | Data Sharing |
|---|---|---|---|---|
| Members (includes Members' families and prospective Members) | To provide our Services to Members, such as: - Onboarding and offboarding - Advising on effective giving - Providing giving support infrastructure - Providing event information - Operating and monitoring the website - Conducting internal analytics for service improvement and impact measurement | Required: Contact Information Identification Information Company Information Financial Information Charitable Giving Information Cookies and Website Analytics Optional: Family Information Religious & Philosophical Beliefs Health Information | Consent Legitimate interests Performance of a contract Explicit consent Compliance with a legal obligation | Third-party systems (e.g. email service providers, CRM, mailing list management software) Other Members (where consent is provided) Event providers / hosts (e.g. hotels, restaurants) |
| Authorised Advisors of a DAF | To provide our Services to Authorised Advisors of a DAF, such as: - Onboarding and offboarding - Providing infrastructure for Members DAF management - Operating and monitoring the website member /app - Conducting internal analytics for service improvement and impact measurement | Required: Contact Information Identification Information Cookies and Website Analytics Optional: Company Information | Consent Legitimate interests Performance of a contract Compliance with a legal obligation | Third-party systems (e.g. email service providers, CRM, mailing list management software) Event providers / hosts (e.g. hotels, restaurants) |
| Donors (includes Donors' families and prospective Donors) | To provide our Services to Donors, such as: - Onboarding and offboarding - Receiving gifts and providing infrastructure for ongoing giving - Operating and monitoring the website - Conducting internal analytics for service improvement and impact measurement | Required: Contact Information Identification Information Financial Information Cookies and Website Analytics Optional: Company Information Family Information Charitable Giving Information | Consent Legitimate interests Performance of a contract Explicit consent Compliance with a legal obligation | Third-party systems (e.g. email service providers, CRM, mailing list management software) Event providers / hosts (e.g. hotels, restaurants) |
| Non-member Donors | To process donations and provide associated giving support, such as: - Processing charitable donations - Administering Gift Aid claims - Issuing donation receipts and confirmations - Operating and monitoring the website - Conducting internal analytics for service improvement and impact measurement | Required: Contact Information Financial Information Optional: Charitable Giving Information | Consent Legitimate interests Performance of a contract Compliance with a legal obligation | Third-party systems (e.g. payment processors, CRM, mailing list management software) HMRC (for Gift Aid administration) |
| Grantees | To provide our Services to Grantees, such as: - Providing grants and making grant payments from our Members and funds - Verifying grantee information - Promoting the work of Founders Pledge and our grantees. This includes publishing (via social media, websites, reports, newsletters or otherwise) identifiable photographs, videos, names, and/or quotes provided by or relating to grantees and individuals associated with funded projects. - Ongoing monitoring of grant conditions | Required: Contact Information Company Information Identification Information | Consent Legitimate interests Performance of a contract Compliance with a legal obligation | Third-party systems (e.g. email service providers, CRM, mailing list management software) Event providers / hosts (e.g. hotels, restaurants) |
| Individuals associated with funded projects (including employees, volunteers, and beneficiaries of grantee organisations) | Promoting the work of Founders Pledge and its grantees, including publishing identifiable photographs, videos, names, and/or quotes in reports, on our website, social media, and newsletters | Names, images, and quotes (as shared with us by grantee organisations) | Consent Legitimate interests | Third-party systems (e.g. website platform, social media platforms, CRM) |
| Suppliers | To facilitate the purchase of goods and services and the ongoing management of contractual relationships | Required: Contact Information Company Information | Consent Legitimate interests Performance of a contract Compliance with a legal obligation | Third-party systems (e.g. email service providers, CRM, mailing list management software) |
| Website/App Users | To provide a functioning website/app experience for all visitors to our website/app, including Members, Authorised Advisors of a DAF, Donors, Grantees, and Suppliers | Required: Cookies and Website Analytics | Legitimate interests | Simple Analytics |
| Event attendees | To manage and facilitate events, such as: - Registering attendance and managing logistics (e.g. dietary requirements, accessibility needs) - Facilitating networking and engagement among attendees - Promoting our events and community. This includes publishing (via social media, website, reports, newsletters, or otherwise) identifiable photographs, videos, names, and/or quotes of attendees. | Required: Contact Information, Company Information Optional: Health Information | Consent Legitimate interests Performance of a contract | Third-party systems (e.g. event management platforms, venue providers) |
| Charity trustees | To manage and facilitate charity governance, oversight, and compliance with legal and regulatory obligations (e.g., filings with the Charity Commission and Companies House) | Contact Information, Identification Information, Biography/Professional details | Compliance with a legal obligation, Legitimate interests | Regulatory bodies (e.g., Charity Commission, Companies House, HMRC), Professional advisors |