Effective Date: July 13, 2023
The Bold.org Privacy Policy (“Privacy Policy”) describes how your personal information is collected, used, and shared when you visit or use the Bold.org, Inc. (“Bold”) website (https://bold.org/) (the “Site”) and when you use and engage our services (“Services”) which includes Personal Information collected via email, SMS, telephone, social media accounts, or other means. At Bold, your privacy is a top priority. By using or accessing the Site or Services, you acknowledge our practices and processing of your information as described in this Privacy Policy.
Please click here for a printable PDF version of this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services on other websites.
In addition, we may from time to time add new sites that may not be listed in this Privacy Policy which are also considered the Site.
Residents in California, Colorado, Connecticut, Utah, and Virginia should refer to the body of this Privacy Policy as well as the section below for additional information that may be applicable to them.
We use the term “personal information” to refer to any information that identifies or can be used to identify you. Common examples of personal information include: name, email address, and IP address and information about a device.
If you are an applicant, we collect personal information from you that includes personal identifiers (such as your name, username, email address, and address), education information (such as your school name, level of education, major, GPA, and standardized test scores), information that may be considered “sensitive” under certain laws (such as citizenship status, ethnicity, religion, age, and gender), financial information (such as your bank account or loan information, including household income, balance and transaction information--including the amount of payments, debits, and deposits--loan balance, interest rate on the loan, and your payment history), and such other information as we may require to provide our Services. Note, that we do not access your personal information directly, however, we may need to access your account as an administrator in order to provide the Services as necessary to remediate any technical bugs or other issues and to improve the Services.
If you are a donor, we collect personal information from you that includes personal identifiers (such as your name, phone number, email address), location (such as your city and state), financial information required to make donations (such as bank account information), and such other information as we may require to provide our Services. Financial information is provided directly to our service provider(s); we do not directly handle donor financial information.
If you contact us, we may collect personal identifiers (such as your name and email address), the contents of your message, and additional information such as your location, and any personal information that you provide in your contact request. We also receive information through your communications with us by email, phone or a physical mail.
We may receive your contact information (including your name, telephone number, and email address) and/or professional or business-related information (including your business address), through our interactions with you in a business-to-business capacity, such as when your business provides services to us, or when we work together on a project, or when we discuss business opportunities. We may contact you with information about our business dealings, news, and opportunities, and we may use your information in the normal course of our business operations.
If you post information on a webpage we establish on a social media platform, we may use the information you provide for purposes of providing a response, to promote our business and services, and otherwise in the normal course of our business operations. We may collect personal identifiers (such as your social media username) and other personal information that you have made available to us through the webpage we established on the social media platform, in accordance with the platform rules and/or applicable law. Note that the third-party operators of social media websites also receive such information, and their use of your personal information is governed by their own privacy policies.
Information automatically collected (through cookies and similar technologies):
When you visit the Site, we and our partners (such as advertising partners and analytics providers) automatically collect certain information about you and your device, including personal identifiers (such as your IP address) and Internet or other electronic network activity information (such as your web browser, and time zone). Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. This information is collected using the following technologies:
For example, we use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your information here. You can also opt-out of Google Analytics here.
Please see our for more details. With respect to any social media platforms on which we have established a webpage, please see the privacy policies and any cookie policies of the applicable social media platform as to their automated data collection practices.
We use your personal information in ways that are compatible with the business and commercial purposes for which it was collected or authorized by you, including for the following purposes.
For applicants, when you register for an account, you will be able to create a financial dashboard within your account that permits you to connect your bank accounts and loans to initiate and permit payments. For donors, when you register for an account, you will be able to provide financial account information that permits you to make donations. Bold does not collect any financial, bank or payment information directly from you. All transactions are handled by a third party payment processor. By using Bold’s Services, you agree that Bold may share your financial, bank or payment information with the third party payment processor.
We may share any of the categories of personal information listed above for our commercial and other business purposes as described below.
Partners (such as scholarship providers, academic institutions, consumer reward providers, data partners (including data modeling, AI and LLM training, big data, and data appending), fraud prevention and detection providers, identity services or identity graph providers, market research providers, healthtech, insuretech, and fintech providers, and bipartisan political campaigns):
Vendors and service providers: We share personal information with vendors and service providers that process such information to perform services for us in connection with the Site, and our other business operations. We require that such vendors and services providers will only use your personal information in a manner that is consistent with this Privacy Policy. This includes technology vendors that may need access to and use of your personal information to give us additional personal information about you. These vendors are bound by law and/or contract to protect the confidentiality and security of your personal information. They only process your personal information to provide requested services for us, and only act on our documented instructions.
Analytics providers. In addition to Google Analytics, we may share your information with other analytics providers, including in an aggregated and anonymous manner, to assess the overall trends and information about our customers and to perform analytics and other work that we may need to outsource. This information will not contain any of your personal information and is only shared in an aggregated and anonymized manner.
Legal and similar disclosures. We may also share your information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
Advertising and marketing partners. Additionally, Bold participates in partner advertising programs designed to provide a means for Bold to generate revenue and be compensated by advertising and linking to those partners’ products or services.
Merger, sale, or other asset transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your personal information may be shared with the other parties and advisors involved under an obligation of confidentiality in connection with the negotiation of such transaction, and your personal information may be transferred as part of such a transaction (subject to compliance with applicable laws).
Please note, we may share aggregated, de-identified personal information with our partners, including our AI partners. We will maintain and use such information in deidentified form and not to attempt to reidentify the information.
The security of your information is very important and we endeavor to process your information securely, in accordance with this Privacy Policy, and in accordance with information security requirements imposed by applicable law.
Although we take reasonable steps designed to protect your information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure.
Certain jurisdictions have specific legal requirements and grant privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. You also have the right to not be discriminated against for exercising your privacy rights. If you are a resident of California, Colorado, Connecticut, Utah, and Virginia, see our Jurisdiction-Specific Notices section below. If you are a resident of another jurisdiction and you seek to exercise your rights under the law of another jurisdiction, please contact us by using the contact information in the How to Contact Us section below.
Please note that, when you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.
We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.
Under certain state privacy laws, our use of cookies and similar technologies may constitute a “sale” or may constitute sharing for behavioral advertising purposes. For additional information, including opt-out rights, see the information available from the "Do Not Sell or Share My Personal Information" link on our Site homepage.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to request that we no longer use your information to provide you services or updates on additional products or for any other reason described in this Privacy Policy, contact us at privacy@bold.org. Additionally, we will retain and use your information as necessary to comply with our legal or regulatory obligations, resolve disputes, and enforce our agreements.
We do not knowingly or intentionally gather personal information about children who are under the age of 14. We also do not knowingly or intentionally share (targeted advertising) or sell (as those terms are defined under U.S. privacy laws) personal information about children who are under the age of 16. If you become aware that a child has provided us with personal information, a child has provided us with personal information, a parent or guardian of that child may contact us at privacy@bold.org to have the information deleted from our records. If we learn that we have inadvertently collected the personal information of a child under 14, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and cease the use of that information in accordance with applicable law.
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA"), California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.
During the last twelve (12) months, we have collected the following categories of personal information from California consumers. Some of the categories of information collected specifically concerns our employees or contractors as opposed to consumers who purchase our products.
Please see our Cookie Policy for information about the collection and use of personal information by third-parties who process information collected by cookies and related technologies that we permit them to use on the Site. Except as indicated above in the “Your Information that We Collect” section, we do not seek to collect any other "sensitive personal information" (as defined in the CCPA).
Category (* may constitute "sensitive personal information" under the CCPA) | Examples | Sold or Shared | Criteria Used to Determine Retention Periods | Disclosed to |
|---|---|---|---|---|
Personal Identifiers | First and last name, email address, and contact address, username, basic account information, IP address, unique identifiers (such as those assigned in cookies) | Yes | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers, Affiliates, Partners, Advertising and Marketing Partners, Analytics Providers |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Name, address, telephone number, employment, employment history | Yes | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers, Affiliates, Partners, Advertising and Marketing Partners, Analytics Providers |
Commercial information | Transaction information, billing records, payment records, order history, auditing, accounting | No | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers and Affiliates |
Electronic, or similar information | Customer support services | No | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers |
Professional or employment related information | Employment history | Yes | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers, Partners, Advertising and Marketing Partners, Analytics Providers |
Internet or other similar network activity | Unique numerical identifier, cookie or tracking pixel information, browsing history, search history, interaction with a website, interaction with an application, or interaction with advertisement, analytics, security, data storage, email and mailing services | Yes | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers, Affiliates, Advertising and Marketing Partners, Analytics Providers |
Geolocation data | Location information (e.g., home address, IP address) | Yes | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers and Affiliates, Partners, Advertising and Marketing Partners, Analytics Providers |
Inferences drawn from other Personal Information | Interests, preferences | Yes | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers, Affiliates, Partners, Advertising and Marketing Partners, Analytics Providers |
Demographic information* | Citizenship status, ethnicity, religion, age, and gender | Yes | The duration of our relationship with you; the length of time necessary to complete a transaction; whether your personal information is a sensitive type; whether you specifically consented to retain the data; and our legal, contractual or similar obligations to retain or delete the data. | Service Providers, Affiliates, Partners, Advertising and Marketing Partners, Analytics Providers |
Under the CCPA, a California resident has the following rights, subject to certain limitations: (1) to request that we disclose to you what Personal Information we collect, use, disclose and sell, including the right to request that we provide you the specific Personal Information we have collected about you in the prior twelve (12) months, (2) to request that we correct inadequate or out of date information, (3) to ask us to delete your Personal Information, (4) to limit the use and disclosure of sensitive personal information, (5) opt-out of the "selling" or "sharing" of personal information, and (6) not to receive discriminatory treatment by us for exercising your privacy rights conferred by the CCPA. You can opt-out from our selling and sharing of your Personal Information as described below (“Do Not Sell or Share My Information”).
You may submit a request to exercise your rights under the CCPA through one of two methods:
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
Upon receiving your request, we will confirm receipt of your request by sending you an email/confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request as soon as reasonably practicable and consistent with any applicable laws. If we require more time, 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. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf through these means. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Colorado residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in “targeted advertising” as that term is defined in the Colorado Privacy Act ("CPA").
Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the “Your Information That We Collect” section. The section above titled, “How We Share Your Information,” describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Colorado, you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; and (4) obtain a copy of your personal information. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.
Connecticut residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in “targeted advertising” as that term is defined in the Connecticut Data Privacy Act ("CTDPA").
Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the “Your Information That We Collect” section. The section above titled, “How We Share Your Information,” describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Connecticut, you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; and (4) obtain a copy of your personal information. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.
Utah residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in “targeted advertising” as that term is defined in the Utah Consumer Privacy Act ("UCPA").
Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the “Your Information That We Collect” section. The section above titled, “How We Share Your Information,” describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Utah, starting December 31, 2023 you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) r