LAST MODIFIED: March 21, 2022
To ensure you are fully informed of our practices, we recommend that you read the entire Policy. However, to make it easier for you to review the parts of this Policy that apply to you, we have divided up the document into sections that are specifically applicable to Customers, Contacts, and Visitors. The remaining information is applicable to everyone.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the end of the Policy.
We understand that when you use the Bonterra Platforms, you are placing your trust in us to appropriately oversee your personal information. It is this trust that serves as the basis for our commitment to take a straightforward and transparent approach to data protection, and part of this approach is ensuring that you have information about how we may collect and process your personal information.
This Policy details our commitment to protecting the privacy of individuals who:
We process the above categories of personal information differently under each Platform because Bonterra the relationship we have with our Customers in processing their data is different from the relationship we have with Contacts in processing their data. However, regardless of the category, “personal information” means any information that identifies or can be used to identify an individual directly or indirectly (e.g., first and last name, date of birth, email address, gender, occupation, or other demographic information) and “you” and “your” means, depending on the context, either a Customer, a Contact, or a Visitor.
Capitalized terms not otherwise defined herein shall have the meaning as set forth herein. In the event of a conflict between this Policy and the Customer’s Agreement, the terms of the Customer’s Agreement will control.
This section applies to the Personal Information we collect and process from a Customer or potential Customer through the provision of the Bonterra Solutions.
Information We Collect
The Personal Information that we collect depends on the context of your interactions with Bonterra Solutions and their respective features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:
Information You Provide to Us. You (or your organization) may provide certain Personal Information to us when you sign up for an and use the Bonterra Solutions, consult with our customer service team, send us an email, integrate a Platform with another service, or communicate with us in any other way. This information may include:
Information We Collect Automatically. When you use the Bonterra Solutions, we may automatically collect or receive certain information about your device and usage of such (collectively “Usage Data”). Usage Data may include:
Information we collect from other sources. From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners. Such information may include demographic information, device information (such as IP addresses), and location (such as city and state). We may use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.
How We Use Personal Information.
We use the Personal Information we collect only in accordance with this Policy, and we never sell your Personal Information to any third party. However, we may use the Personal Information we collect or receive through the Bonterra Solutions (alone or in combination with other data we source) for the purposes and on the legal bases identified below:
Product Specific Disclosures.
Non-Bonterra Solutions Applications.We may use the Personal Information we collect or receive through a Platform, as a processor and as otherwise stated in this Policy, to enable your use of the integrations you choose to connect to your account. For instance, if you choose to connect a Google integration to your account, we will ask you to grant us permission to view and/or download, as applicable, your Google Sheets and Google Drive. This allows us to configure your Google integration(s) in accordance with your preferences. Conversely, if you give an integration provider access to your account, then your use of those integrations is subject to the service terms and privacy terms made available by that integrator. We are not responsible for third-party integrators and in no case are such integration providers our sub-processors.
Distribution Lists. To enable you and your authorized users the ability to send an email, SMS, or calling campaign or use certain features in your account, you need to upload a distribution list that provides us information about your donors or constituents, such as their names, email addresses, and mobile phone numbers. We use and process this information to provide the requested services in accordance with our contract with you or your organization and this Policy. We do not, under any circumstances, sell your distribution lists; however, if someone on your distribution list complains or contacts us, we might then contact that person. If we detect abusive or illegal behavior related to your distribution list, we may share your distribution list or portions of it with affected mobile carriers, ISPs, or anti-spam organizations to the extent permitted or required by applicable law.
Single Sign-On. You can log in to certain Platforms using a Single Sign-on(SSO) service like your Facebook or Twitter account. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name.
Cookies and Tracking Technologies.
This section applies to Personal Information that we collect and process when you visit one of our websites, and in the usual course of our business, such as in connection with our sales and marketing activities.
Information We Collect.
When you visit our website, sign up for an event or request more information about Bonterra, we Collect information automatically using tracking technologies, like cookies, and through web forms where you type in your information. We collect this information to provide you with what you request through the web form and to improve navigation experience on our pages.
Information You Provide Us. On our public-facing websites, you can fill out web forms to ask to be contacted by our sales Team, sign up for a weekly newsletter, register for a webinar, or donate or contribute to the political candidate or nonprofit cause of your choice. The Personal Information requested on these forms will vary based on the purpose of the form. We will ask you for information necessary for us to provide you with what you request through the form (e.g., we will ask you for your email address if you want to signup for an email newsletter). If you sign up to receive ongoing marketing communications, you can always choose to opt out of further communications through a link contained in every marketing email you receive from Bonterra.
Information We Collect Automatically.
How We Use Your Personal Information.
Public Information and Third-Party Websites.
Social Media Platforms and Widgets. Certain of our websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. We also maintain a presence on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
Bonterra processes Personal Information of Contacts under the direction of our Customers and has no direct control or ownership of the Personal Information of a Contact we process on behalf of our Customers. Our Customers are responsible for complying with any regulations or laws that require providing notice, disclosure, and obtaining consent prior to transferring the Contact information to Bonterra for processing purposes.
Data protection law (including privacy law) in certain jurisdictions, like the EEA, Switzerland and the United Kingdom, differentiate between “controllers” and “processors” of Personal Information. When Bonterra processes Personal Information regarding you submitted by one of our Customers, we act as a processor in nearly all respects.
Information We Receive About Contacts from Our Customers.
Certain Bonterra Solutions allow our Customers to collect and store the Personal Information of a Customer’s donors, contributors, constituents, or prospects. We have no direct relationship with individuals who provide Personal Information to our Customers. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring any Personal Information belonging to one of its Contacts to Bonterra for processing purposes.
Bonterra processes Contact data on behalf of, and as directed by, the Customer in accordance with and restricted by our agreements with our Customers. Bonterra can only process the Contact data for certain specific and limited purposes; namely, to fulfill our contractual obligations under the Agreement and, in narrow instances, to improve our Platforms or as permitted by this Policy or as required by law. Bonterra neither controls the content of the Contact data, determines the types of Personal Information that a Customer chooses to store in the Platform, nor has direct control or ownership of the Contact data we process on behalf of our Customers. Rather, our Customers make those decisions based on, and in accordance with, their respective privacy policies.
Our Customers control and are responsible for correcting, deleting, or updating information they have collected from using the Platforms. Please direct any inquiries or requests to exercise any data rights you may have to the applicable customer.
Information We Collect Automatically.
When you interact with a Customer, we may collect information about your device and interaction in specific, limited, and typically in an aggregated or anonymized manner. For example, it is important for us to ensure the security and reliability of the Bonterra Solutions. Therefore, we may collect data about your interactions with our Customer’s campaigns (and/or emails) sent through a Platform, which may include dates and times you access an email. This information also allows us to ensure compliance with this Policy and our Acceptable Use Policy, to monitor and prevent service abuse, and to ensure we collect information regarding the performance of the Bonterra Solutions, including metrics related to the deliverability of the Platforms. This information allows us to improve the content and operation of the Bonterra Solutions and facilitate research and perform analysis into the use and performance of the same.
How We Use Personal Information.
We may use the Personal Information we collect or receive about you in reliance on our (and where applicable, our Customers’) legitimate interests for the following purposes:
We do not sell a Contact’s Personal Information to any third party for its marketing, or any other, purpose.
Reviewing, Correcting, and Removing Your Personal Information.
Depending on the country in which you reside, you may have the following data protection rights:
To exercise any of these rights, please contact us at email@example.com or by mail to Bonterra, LLC., 10801 North MoPac Expressway, Suite 400, Austin, TX 78759 USA, Attention: Data Protection Officer. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity to help us respond efficiently to your request.
Your Preferences for Email and SMS Marketing Communications.
Bonterra does not send marketing communications to Contacts; however, you may receive SMS, e-mail, or other communications sent through our Platforms by our Customers. Bonterra is not responsible for our Customer’s communications sent to you. To opt-out of receiving further communications, please follow the “unsubscribe” or “opt-out” protocol contained in the communication or contact the sender (i.e., Customer) of the communication. If you contact Bonterra, we will be unable to address your request, but we may forward your request to the particular Customer under certain circumstances.
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by emailing us at firstname.lastname@example.org or postal mail to Bonterra, LLC, 10801 North MoPac Expressway, Suite 400,Austin, TX 78759 USA, Attention: Data Protection Officer. Customers cannot optout of receiving transactional emails related to their account with us or the Bonterra Solutions.
California Privacy Rights.
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Customers with whom you have a relationship and under certain circumstances us)disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering services to its Customers, Bonterra acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Customers in order for us to provide the Bonterra Solutions. Please direct any requests for accessor deletion of your Personal Information under the CCPA to the Customer with whom you have a direct relationship.
This section applies solely to Customers, Visitors and Contacts who qualify as a “consumer” under the California Consumer Privacy Act of 2018 (CCPA) and reside in the State of California (“Consumers” or “you”). Any capitalized terms not defined elsewhere in this Policy shall have the meaning ascribed to it in the CCPA, and solely for this section the term “Personal Information” has the meaning given in the CCPA and not as defined and used elsewhere in this Policy. Personal information does not include:
How We Collect, Use, and Share Your Personal Information.
We have collected the following categories of Personal Information from Consumers within the last twelve (12) months:
The business and commercial purposes for which we collect this Personal Information are described under the Customer, Visitor, and Contacts sections of this Policy, and the third parties to whom we “disclose” your Personal Information is contained under the section entitled, How Bonterra Shares Personal Information.
Your California Rights.
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to you:
We do not provide these access and data portability rights for B2B Personal Information.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We do not provide these deletion rights for B2B Personal Information.
Bonterra does not “sell” Personal Information to third parties as that term is defined in the CCPA.
Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to us by using the contact information in the Contact Us section of this Policy.
Only you, or someone legally authorized to act on your behalf, may make a verifiable Consumer request related to your Personal Information. You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. The verifiable Consumer request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable Consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format.
We endeavor to respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable Consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically a .csv file.
We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
If you have any questions or comments about this section, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at the information provided in the Contact Us section of this Policy.
How Bonterra Shares Personal Information.
We do not sell or allow your Personal Information to be used by third parties for their own marketing purposes. Below are the different scenarios under which we may share your data with third parties.
Legal Basis for Processing Personal Information (EEA visitors only).
If you are a visitor located in the European Economic Area (“EEA”),our Data Protection Officer can be contacted at email@example.com. Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In certain cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information). Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
How to Make Choices About Your Personal Information.
You can make various choices about collection and retention of your Personal Information through the associated account portal, such as accessing it, correcting it, deleting it, or updating your choices about how it is used. Any other requests about your data you cannot make through these self-service tools, you can request by emailing firstname.lastname@example.org.
Closing Your Account and Deletion. To request closure or deletion of an account, you can email us at email@example.com. Please contact the administrator for your Platform account regarding closing or deleting your account. You should know that closure and/or deletion of your account will result in you permanently losing access to your account and data in the account. Please note that certain information associated with your account may nonetheless remain on our servers in an aggregated form that does not identify you. To cancel an authorized user’s account, your account administrator can delete or disable the authorized user’s account in the administrator’s account management portal. However, irrespective of type of account, data, including personal information, associated with such account that we are required to maintain for legal purposes or for necessary business operations will be retained after account closure until no longer needed.
Promotional Communications. You can choose not to receive promotional emails from Bonterra by following the unsubscribe/opt-out instructions in those emails. You can also opt-out by contacting firstname.lastname@example.org. Please note that even if you opt out of promotional communications, we may still send you non-promotional messages relating to things like updates to our privacy notices, security alerts, and other notices relating to your access to or use of our products and services.
For Customers and Visitors.
Cookies and Tracking Technologies. How you make choices about cookies and other tracking technologies depends on the type of cookie or tracking technology being used. For details on how to manage your preferences for cookies and tracking technologies, please check out our Cookie Notice.
Other Choices About Your Data. In addition, you can express other choices about your information (i.e., restricting its use, porting it, or withdrawing consent for its use) by contacting email@example.com. Please be aware that if you provided your Personal Information as part of entering into a contract with Bonterra, that contract may provide more details on retention of or your rights to such information.
As described above, for much of the Personal Information we collect and process about Contacts through the Bonterra Solutions, we act as a processor on behalf of our Customers. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Bonterra as a processor on behalf of our individual Customers, you should contact the relevant Customer that is using the Bonterra Solutions and refer to their separate privacy policies.
If you no longer want to be contacted by one of our Customers, please unsubscribe directly from that Customer’s newsletter or contact the Customer directly to update or delete your data. If you contact us directly, we may either forward your request to the relevant Customer or provide you with the identity of the Customer to enable you to contact them directly.
How We Secure Personal Information.
We use appropriate security measures to protect the security of your Personal Information both online and offline. These measures vary based on the sensitivity of the Personal Information we collect, process and store and the current state of technology. We also take measures to ensure service providers that process Personal Information on our behalf also have appropriate security controls in place.
Please note that no service is completely secure. While we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss, or a data breach will never occur.
To protect the confidentiality of your account and protect from unauthorized use of your account, we recommend enabling two-factor authentication for your account. Additionally, you must keep your account password confidential and not disclose them publicly or to unauthorized individuals — this includes accidentally distributing them in a binary or checking them into source control. Please let your account administrator and Bonterra know right away if you think your password was compromised or misused. Similarly, if you provision an API Key, you should secure your access credentials to the API Key as well.
Transfers of Personal Information Out of the EEA, Switzerland and the United Kingdom.
We operate in the United States.
Our servers and offices are in the United States, so your Personal Information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy. Customers located in Switzerland, United Kingdom, and the EEA are subject to each of our Platforms specific Data Processing Agreement. Please visit the Data Processing Agreement for each applicable Platform to view the terms for compliance with the General Data Protection Regulation(GDPR), EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. In certain circumstances, we may rely on the European Union Model Clauses, also known as Standard Contractual Clauses, involving transfers of Personal Information from Switzerland and EEA to the United States and on the United Kingdom’s international data transfer agreement and international data transfer addendum to the Standard Contractual Clauses involving transfers of Personal Information from the United Kingdom to the United States.
Retention of Your Personal Information.
Details regarding how long your Personal Information may be stored on our systems will depend on whether you are a Customer, Visitor, or Contact. Generally, we will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes for which it was collected or placed into our systems. Without limiting the generality of the foregoing, here is an overview of how long we hold on to Personal Information in a form that can be used to identify you:
Customers. As an Bonterra Customer, we will retain these records for as long you instruct. In some cases, use of extended storage may cost more. If you later instruct us to delete those records, we will do so. Please note that it may take 30 days or longer for the data to be completely removed from all systems.
Visitors. Generally, we retain your Personal Information for only as long as needed to fulfill the purposes for which it was collected; however, certain Visitors to our Customer’s donation or giving webpages may have their Personal Information stored through the use of a cookie up to 10 years to allow prepopulating of web forms on the same or other Customer donation or giving webpages.
Contacts. If the Bonterra Solutions enable a Customer to store records of your Personal Information contained within its data, and that Customer chooses to do so, then we will retain this data for as long our Customer instructs, subject to applicable law. You should direct requests seeking further information relating to retention of your Personal Information to the relevant Customer to address.
Deletion Request. If you are a Customer or Visitor and you ask Bonterra to delete specific Personal Information about you, we will honor this request in accordance with applicable law. If you are a Contact or an end user of a Non-Bonterra Application, you should direct requests to the relevant Customer or application provider.
We may retain your Personal Information for a longer period as necessary to carry out necessary business functions (e.g., billing for our products and service) or for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements, such as in the event of a complaint or if we believe there is a prospect of litigation in respect to our relationship with you. However, after expiry of the applicable retention periods, we will delete your Personal Information. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
Information from Children.
We do not knowingly permit children (under the age of 13 in the US or 16 if you live in the EEA, Switzerland or the United Kingdom) to sign up for the Bonterra Solutions. If we discover someone who is underage has signed up for access to the Bonterra Solutions, we will take reasonable steps to promptly remove that person’s Personal Information from our records. If you believe a person who is underage has signed up for access to the Bonterra Solutions or has been included as a Contact, please contact us at firstname.lastname@example.org.
Do Not Track (“DNT”)is a privacy preference that you can set in most web browsers. Certain state laws require us to indicate whether we honor DNT settings in your browser. Bonterra currently supports DNT; however, there is no accepted standard on how to respond to web browsers’ DNT signals and even when you have DNT enabled, we may still use information collected for analytics and measurement purposes or to otherwise provide the Bonterra Solutions, but we will not load any third-party trackers. You can learn more about Do Not Track here, and you can learn more about the cookies our websites set here.
Changes to Our Privacy Notice.
We may change our Policy from time to time. If we make changes, we’ll revise the “Last Modified” date at the top of this Policy, and we may provide additional notice such as on the Bonterra website homepage, account portal sign-in page, or via the email address we have on file for you. We will comply with applicable law with respect to any changes we make to this notice and seek your consent to any material changes if this is required by applicable law.
To exercise your rights regarding your Personal Information, or if you have any questions regarding this Policy or our privacy practices, please email us at email@example.com or write to us at:
Bonterra LLC., Attn: Data Protection Officer, 10801North MoPac Expressway, Suite 400, Austin, TX 78759
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.
If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, the United Kingdom, or Switzerland, you have the right to lodge a complaint with the competent supervisory authority.