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Subsplash Customer Privacy Policy

Last updated May 24, 2018. Version 3.6

This privacy policy describes the collection, use, protection, disclosure, correction and deletion of your personal information by Subsplash.  Please take a moment to read the following to learn more about our information practices, including what type of information is gathered, how the information is used and for what purposes, to whom we disclose the information, and how we safeguard your personal information.  Your privacy is a priority at Subsplash, and we go to great lengths to protect it.

This privacy policy applies to the websites located at subsplash.com and thechurchapp.com, including all subpages and successor pages, as well as all software and services that we offer, including but not limited to those services that we offer through our websites when you register for a Subsplash account (collectively referred to as the “Subsplash Account Services”).

Subsplash may update its privacy policy from time to time.  When we change the policy in a material way a notice will be posted on our website along with the updated privacy policy.

 

Why we collect personal information

We collect your personal information because:

  • It helps Subsplash deliver the Subsplash Account Services;
  • It helps Subsplash deliver a superior level of customer service;
  • It enables Subsplash to give you convenient access to our products and services and focus on categories of greatest interest to you;
  • It helps Subsplash keep you posted on the latest product announcements, software updates, special offers, and events that you might like to hear about. If you do not want Subsplash to keep you up to date with Subsplash news, software updates and the latest information on products and services please send an email request to privacy@subsplash.com.

What information we collect, when we collect it, and how we may use it

If you wish to utilize Subsplash Account Services, Subsplash needs your information for purposes of processing and transmitting information to drive the correct data and content between servers and apps for your experience.

Also, there are a number of situations in which your personal information may help us give you better service.  For example:

  • We may ask for your personal information when you’re discussing a service issue on the phone with an associate, downloading a software update, registering for a seminar, participating in an online survey, registering your products, or purchasing a product;
  • When you interact with Subsplash, we may collect personal information relevant to the situation, such as your name, mailing address, phone number, email address, and contact preferences; your credit card information and information about the Subsplash products you own, such as their serial numbers and date of purchase; and information relating to a support or service issue;
  • We collect information regarding customer activities on our websites and applications.  This helps us to determine how best to provide useful information to customers and to understand which parts of our websites, products, and Internet services are of most interest to them;
  • When you visit the Subsplash mobile application, we may ask you to opt in to allow us to use GPS technology (or other similar technology) to determine your current location for purposes of reporting on user activity and engagement.  If you do not want us to use your location for the purposes set forth above, you should not opt in or turn off the location services for the Subsplash mobile application located in your account settings or in your mobile phone settings and/or within the mobile application;
  • We may use personal information to provide products and/or services that you have requested as well as for auditing, research, and analysis to improve Subsplash’s products.

Publicly displayed information is public 

If you use a bulletin board or chat room on a Subsplash website you should be aware that any information you share is visible to other users.  Personally identifiable information you submit to one of these forums can be read, collected, or used by other individuals to send you unsolicited messages.  Subsplash is not responsible for the personally identifiable information you choose to submit in these forums. For example, if you choose to make information, which was previously non-public, available by enabling certain user features, Subsplash will collect that information from your interaction and the information will become publicly available.

When we disclose your information 

Subsplash takes your privacy very seriously.  Subsplash does not sell or rent your contact information to other marketers or any other third party.  If you wish to utilize the Subsplash Account Services, Subsplash discloses your information to third party service providers and institutions for purposes of processing and transmitting information to drive the correct data and content between servers and apps for your experience.

Within the Subsplash Group

Subsplash, Inc. and Subsplash Wallet, LLC both operate under the name “Subsplash” and they operate as a group.  To help us provide superior service, your personal information may be shared with legal entities within the Subsplash group globally who will take reasonable steps to safeguard it in accordance with Subsplash’s privacy policy.

With our service providers, vendors, and strategic partners

There are also times when it may be advantageous for Subsplash to make certain personal information about you available to companies that Subsplash has a strategic relationship with or that perform work for Subsplash to provide products and services to you on our behalf.  These companies may help us process information, extend credit, fulfill customer orders, deliver products to you, manage and enhance customer data, provide customer service, assess your interest in our products and services, or conduct customer research or satisfaction surveys.  These companies are also obligated to protect your personal information in strict accordance with Subsplash’s policies, except if we inform you otherwise at the time of collection. Without such information being made available, it would be difficult for you to purchase products, have products delivered to you, receive customer service, provide us feedback to improve our products and services, or access certain services, offers, and content on the Subsplash website.

Lawful requests

At times we may be required by law or litigation to disclose your personal information.  We may also disclose information about you if we reasonably determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary.

Subsplash Giving

Subsplash Giving is web-enabled functionality that can be used with a web browser and on mobile devices.  It was developed by Subsplash to enable donors to donate money to third-party organizations. If you choose to use the Subsplash Giving functionality to donate money, Subsplash and the payment processor will collect personal information from you, including your name, contact information, the donation amounts, and the payment processor receives certain payment information (e.g. credit card number, billing address, security code) and will use that information to process payments and provide you records of the transactions.  Donor information will be shared with the Gift Recipient.

Cookies and other technologies

As is standard practice on many corporate websites, Subsplash’s websites use “cookies” and other technologies to help us understand which parts of our websites are the most popular, where our visitors are going, and how much time they spend there.  We also use cookies and other technologies to make sure that our online advertising is bringing customers to our products and services. Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.

If, however, you prefer not to enable cookies, you can disable them in your browser.  Please note that certain features of the Subsplash websites and Subsplash online products will not be available once cookies are disabled.  As is true of most websites, we gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We also use Google Analytics. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website.   

Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.

We also may use other Google Analytics tools, such as Demographics and Interest Reporting, which enable us to learn more about the characteristics and interests of the users who visit our Site, and Remarketing with Google Analytics, which enables us to provide relevant advertising on different websites and online services.

Google Analytics collects information anonymously.  It reports website trends without identifying individual visitors.  You can opt out of Google analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across websites you use, visit this Google page

We use this information, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.

In some of our email messages we use a “click-through URL” linked to content on the Subsplash website.  When customers click one of these URLs, they pass through our web server before arriving at the destination web page.  We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications.  If you prefer not to be tracked simply avoid clicking text or graphic links in the email. In addition, we use pixel tags — tiny graphic images — to tell us what parts of our website customers have visited or to measure the effectiveness of searches customers perform on our site.

Pixel tags also enable us to send email messages in a format customers can read.  And they tell us whether emails have been opened to ensure that we’re sending only messages that are of interest to our customers.  We may use this information to reduce or eliminate messages sent to a customer.

How we protect your personal information

Subsplash takes precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.  The Subsplash websites use Secure Sockets Layer (SSL) encryption on all web pages where personal information is required. To make purchases from the Subsplash online store, or through your Subsplash accounts, you must use an SSL-enabled browser such as Safari, Google, or Internet Explorer.  Doing so protects the confidentiality of your personal and credit card information while it’s transmitted over the Internet. You can help us by also taking precautions to protect your personal data when you are on the Internet. Change your passwords often using a combination of letters and numbers, and make sure you use a secure web browser like Safari or Google.

Integrity of your personal information

Subsplash allows you to keep your personal information accurate, complete, and up to date.  Naturally, you have the right to access, correct and delete the personal information you have provided, though you may not delete all information if you wish to maintain an account with Subsplash and Subsplash is required to retain some information with regard to Subsplash Giving transactions and donors.  Despite our best efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let us know and we will make the corrections promptly and use every reasonable effort to communicate these changes to other parties who may have inadvertently received incorrect or out-of-date personal information from us.  In the event that you delete your information, such deletion may make it impossible for Subsplash to continue offering you some or all of the Subsplash Account Services.

Subsplash retains personal information only as long as we are required to for our business relationship or as required by Federal or Provincial laws, subject to reasonable industry practices for records retention.  Subsplash has appropriate procedures in place with respect to the destruction, deletion and disposition of personal information when it is no longer required by Subsplash, subject to applicable law.

Children

Subsplash recognizes that parents, guardians, or other adults often purchase our products for family use, including use by minors.  We do not knowingly collect personal information from children under the age of 13 for marketing purposes, but because some information is collected electronically, it can appear to be the personal information of the Subsplash purchaser of the product, and will be treated as such by this privacy policy.  If a child under the age of 13 submits personal information to Subsplash and we learn that that personal information is the information of a child under the age of 13, we will attempt to delete the information as soon as possible.

Canada Customers

Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (Canada), the Privacy Act (Canada) and all provincial statutes that regulate the treatment of personal information in the private and public sectors.

Depending on the location of users of the Subsplash Account Services, information on in the Subsplash Account Services including the Subsplash website may be accessed from outside of Canada or sent to others outside of Canada.  Please note that any personal information that is sent outside of Canada may be subject to access by law enforcement and government authorities having jurisdiction in those countries in which the information is located.

If the event that any dispute between you and Subsplash regarding your personal information or this policy is not resolved pursuant to the “Dispute Resolution” section below within thirty (30) days, either party may consult the Privacy Commissioner of Canada or a relevant provincial privacy commissioner.

EU-US Privacy Shield Framework; GDPR

The following provisions govern information collected in reliance on the EU-U.S. Privacy Shield Framework Principles for transfers of personal data from the EU to the United States.  Subsplash adheres to the Privacy Shield Principles (“Principles”) and is committed to subject to the Principles all personal data received from the EU in reliance on the Privacy Shield.  Individuals from whom Subsplash collects personal information under the Privacy Shield have the right to access their personal data by contacting Subsplash at privacy@subsplash.com. As a result of certification to the Privacy Shield, Subsplash is subject to the investigatory and enforcement powers of the FTC, the Department of Transportation, or any other U.S. authorized statutory body.

You may access the Privacy Shield List here. 

Notice and Choice

When Subsplash collects personal information from individuals, it may share this information with its client organizations or third parties as described above in the Privacy Policy. Individuals should review the privacy policy of the client organization. Individuals will have the choice of signing up for Subsplash services or not.  A link to the Subsplash privacy policy will be provided when individuals are first asked to provide personal information when opting in to Subsplash services.

In instances in which Subsplash is not the controller or collector of the personal information, but only a processor, it has no means of providing individuals with the choice and means for limiting the use and disclosure of their personal information or providing notices when individuals are first asked to provide personal information to Subsplash.  In such instances, Subsplash will comply with the instructions of the controller of such information; provide appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and to the extent appropriate, assist the controller in responding to individuals exercising their rights under the Principles.

Disclosures to Third Parties

Subsplash will not make disclosures of personal information to third parties without notifying individuals that such disclosure may be made.  In those instances in which Subsplash collects personal information from individuals, prior to disclosing personal information to a third party, Subsplash shall notify the individual of the fact that their information may be disclosed. If individuals do not wish to have their personal information disclosed to any third parties, the individual should not register for such Subsplash services.  With regard to Subsplash Giving, donor information will be shared with the Gift Recipient. The Gift Recipient may utilize a third party for purposes of receipt and management of such information and donors should review the privacy policies of Gift Recipient in this regard. In the case of third parties (e.g., churches) for whom Subsplash gathers personal information, Subsplash shall enter into a contract that provides that such data may only be processed for limited and specified purposes consistent with consent provided and that such third party will provide the same level of protection as is required by the Principles.  For third party agent recipients (e.g., payment processors) of personal information, Subsplash shall: transfer only such data for limited and specified purposes; ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles, and; upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing.

Data Security

Subsplash shall take reasonable steps to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Subsplash has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Subsplash cannot guarantee the security of information on or transmitted via the Internet.

Data Integrity

Subsplash shall only process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by those who provided the information. To the extent necessary for those purposes, Subsplash shall take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

Access

In those instances in which Subsplash collects personal information directly from individuals, Subsplash shall allow those individuals access to their personal information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.  As noted above, you may not delete all information if you wish to maintain an account with Subsplash and Subsplash is required to retain some information with regard to Subsplash Giving transactions and the applicable users.

Recourse, Enforcement, and Liability

a)  Dispute Resolution

If you filed a complaint with Subsplash and it has not been properly addressed, JAMS is designated by Subsplash as the independent dispute resolution body to address complaints regarding Subsplash’s collection of personal information and provide appropriate recourse.  Such body will not charge the complaining party for its services. Follow this link to the complaint submission form for the above referenced independent dispute resolution body.

b)  Binding Arbitration

If your claims as to data covered by the EU-U.S. Privacy Shield have not been remedied through dispute resolution directly with Subsplash or through independent dispute resolution as described above, such “residual claims” may be heard by a “Privacy Shield Panel” composed of one or three arbitrators as agreed upon by the parties.  The Privacy Shield Panel may only award individual-specific, non-monetary equitable relief (e.g. access, correction, deletion of the individual’s data in question) necessary to remedy the violation of the Principles only with respect to the individual. Damages, costs, fees and other remedies may not be awarded, and each party bears its own attorney’s fees.  This arbitration option is only available for an individual to determine for such “residual claims” whether Subsplash has violated its obligations under the Principles as to that individual and whether any such violation remains fully or partially unremedied.

c) GDPR (General Data Protection Regulation)

The GDPR replaces Directive 95/46/EC and becomes enforceable on May 25, 2018. The following statement is intended to supplement the preceding discussion of the EU-U.S. Privacy Shield. As to personal data collected and controlled by Subsplash, subject to the qualifications and limitations stated in the preceding discussion, EU data subjects retain their full rights to be informed of the purposes of our processing activities at collection; to withdraw consent; to access, rectify, transport, and erase their personal data; to object to processing for direct marketing efforts; and to object when subjected to automated processing decisions. As to personal data collected by third parties, and as to which Subsplash is a mere processor, EU data subjects should contact the controller (e.g., church or ministry) with regard to their rights to be informed of the purposes of our processing activities at collection; to withdraw consent; to access, rectify, transport, and erase their personal data; to object to processing for direct marketing efforts; and to object when subjected to automated processing decisions.  Such rights may be subject to certain qualifications and limitations as stated in the discussion of EU-US Privacy Shield.

Our Data Processing Officer—Justin Lohman—will assist EU residents with these requests free of charge and may be contacted at privacy@subsplash.com.

Subsplash understands that the adoption of global data security practices is not a one-time activity.  Subsplash’s “privacy by design” approach requires that our default user data protection levels be at the highest setting by default. In the unlikely event of breach, Subsplash will notify data subjects and Supervisory Authorities (SAs) in the EU according to procedures provided in GDPR Articles 33 and 34.

We do not intentionally collect personal data from, and do not tailor any services to, children.

Our companywide commitment to your privacy

To make sure your personal information is secure, we communicate these privacy guidelines to Subsplash employees and strictly enforce privacy safeguards within the company.

Freedom of information requests

If you are communicating with or making a donation to any organization or institution that is subject to either federal or provincial public sector “freedom of information” or “access to information” legislation, then please note that information concerning your communication and/or donation may disclosed to third parties pursuant to the procedures available under those laws.

Inquires, complaints, and dispute resolution

If you wish to verify, correct or delete any personal information we have collected, or if you have any questions or concerns, or if you have any complaints, please contact privacy@subsplash.com. If there is a dispute between you and Subsplash regarding your personal information or this policy, you agree to use reasonable efforts to resolve such dispute with Subsplash informally and to consult and negotiate with Subsplash in good faith to reach a fair and equitable solution.  

Privacy questions

If you have questions or concerns about Subsplash’s privacy policy, please contact our Privacy Officer.  Our Privacy Officer can be contacted at:

Subsplash, Inc. 3257 16th Ave W, Seattle, Washington, USA 98119 or privacy@subsplash.com