Privacy Policy

This Privacy Notice for Velvet Frame LLC ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at velvetframe.org or any website of ours that links to this Privacy Notice
• Use our impact philanthropy advisory services
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@velvetframe.org.

Summary of Key Points

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by reading the full notice below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Table of Contents

1. What Information Do We Collect?
2. How Do We Process Your Information?
3. What Legal Bases Do We Rely On to Process Your Personal Information?
4. When and With Whom Do We Share Your Personal Information?
5. Do We Use Cookies and Other Tracking Technologies?
6. How Long Do We Keep Your Information?
7. How Do We Keep Your Information Safe?
8. Do We Collect Information from Minors?
9. What Are Your Privacy Rights?
10. Controls for Do-Not-Track Features
11. Do United States Residents Have Specific Privacy Rights?
12. Do Other Regions Have Specific Privacy Rights?
13. Do We Make Updates to This Notice?
14. How Can You Contact Us About This Notice?
15. How Can You Review, Update, or Delete the Data We Collect from You?

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Phone numbers
• Email addresses
• Mailing addresses
• Job titles
• Debit/credit card numbers
• Billing addresses

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by HoneyBook. You may find their privacy notice link(s) here: https://www.honeybook.com/legal/privacy.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.

Google API. Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On to Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, the General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, we may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout.

6. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. Do We Collect Information from Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@velvetframe.org.

9. What Are Your Privacy Rights?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided below.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.

If you have questions or comments about your privacy rights, you may email us at hello@velvetframe.org.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of certain US states, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights include: Right to know whether or not we are processing your personal data; Right to access your personal data; Right to correct inaccuracies in your personal data; Right to request the deletion of your personal data; Right to obtain a copy of the personal data you previously shared with us; Right to non-discrimination for exercising your rights; Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling.

How to Exercise Your Rights: To exercise these rights, you can contact us by emailing us at hello@velvetframe.org, or by referring to the contact details at the bottom of this document.

12. Do Other Regions Have Specific Privacy Rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand: We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020.

Republic of South Africa: At any time, you have the right to request access to or correction of your personal information.

13. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at hello@velvetframe.org or contact us by post at:

Velvet Frame LLC
PO Box 38397
Elmont, NY 11003-8397
United States

15. How Can You Review, Update, or Delete the Data We Collect from You?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please contact us at hello@velvetframe.org.