Welcome to our Privacy Policy. The terms “we”, “us”, and “our” refer to GVI Charitable Programs, a non-profit entity exempted under Section 501(c)(3) of the Internal Revenue Code. This privacy policy is referenced in our Website Terms of Use available on this site. We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. You must accept the Terms of Use as well as this Privacy Policy in order to use the site and Service. Please note that the Terms of Use and this Privacy Policy are subject to change. Any changes to the Privacy Policy will be made available on this webpage. 





This Privacy Policy aims to give you information on how GVI Charitable Programs collects and processes your personal data through your use of this website, including any data you may provide through this website when you download content, sign up to our newsletter, donate or enquire. 


This website is not intended for children and we do not knowingly collect data relating to children. If you are below the age of 16 then you must have your parent’s or legal guardian’s consent to submit any personal data at all. We will promptly delete any personal information relating to minors where we are informed that parental or guardian consent has not been granted. Should you be a concerned parent or guardian of a minor who has submitted their personal data without your consent please write to our Data Protection Officer for assistance.


It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.





If you have any questions about this policy, we welcome you to contact us:


Full name of legal entity: GVI Charitable Programs



Contact Person: Laura Dix-Bowler


Email address : [email protected]


Mailing address:


Address: 75 State Street, 


Floor 1&2


Boston, MA 02110


EIN 84-2009644


Registered 501 (c) (3) non-profit organization


Telephone number: +1888660-0565





It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.





This website and our service may include links to third-party websites, plug-ins, and services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. Such services may include applications like Zoom or Canvas, as required to deliver the service to you. Please note that your personal data as entered into any such service may be visible to other people using the same service and or other people enrolled for the same or a similar program to you. When you leave our website or use any of these third-party resources and services, we encourage you to read their Privacy Policies. 





Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 


We may collect, use, store, and transfer different kinds of personal data about you. Some of the data may constitute Personal Information only when combined with personal identifiers. We have grouped the data for your reference as follows:


– Identity Data may include first name, maiden name, last name, username or similar identifier, title, date of birth, and gender.


– Contact Data may include email addresses and telephone numbers.


– Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.


– Technical Data may include internet protocol (IP) addresses, your login data, browser type, and version, timezone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites and services.


– Usage Data may include information about how you use our websites, products, and services.


– Marketing and Communications Data may include your preferences in receiving marketing from us and our third parties and your communication preferences.





Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may be unable to process your donation or respond to your inquiry. We will notify you if this is the case at the time. 





We use different methods to collect data from and about you including through: 


– Direct interactions. You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal information you provide when you: apply for our Programs or register on the site or the Service; request marketing to be sent to you; provide any other personal information to us directly by post, phone, email, or in-person; respond to a survey or enter into our promotions and competitions; engage with us via social media; use the Message Board features of the Service and include personal information directly or indirectly (eg. via a display name).


– Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy below for further details.


 -Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below :


– Technical Data from the following parties:


– (a) analytics providers such as Google Analytics


– (b) advertising networks such as Google Adwords, Facebook, and Bing




We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 


– When we need to report donations to the Internal Revenue Service as required by law.


– Where we need to perform the contract we are about to enter into or have entered into with you.


– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.


– Where we need to comply with a legal or regulatory obligation.


Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. 





We will only collect and process personal data about you where we have one or more lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, vital interests, and where relevant “legitimate interests”. 





We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 





You will receive marketing communications from us if you have opted to do so while requesting other information from us or when making a booking.






You can ask us or third parties to stop sending you marketing messages at any time by using the unsubscribe link included in the footer of all marketing messages. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us when you donate.  





You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy below.





We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.





We may have to share your personal data with the parties set out below for the purposes of providing services to you or performing our contract with you. 


– Third parties who perform work on our behalf or work with us including, without limitation, third-party service providers, agents, vendors, payment processors, consultants, and attorneys (“Service Providers”).


– Third-party vendors: who provide services or functions on our behalf, such as credit card processing, business analytics, support, and fraud prevention. Such vendors are not permitted to share or use the information for any other purpose other than performing the specific functions they provide.


We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.





Your Personal Information may be stored and processed in any country where we have volunteers or in which we engage service providers, and, by using this Website, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.


We are part of a global network, and there are instances in which we may share your data within our Network. We may need to transfer your personal data to suppliers based in the US or other countries outside of the European Economic Area (EEA) to allow them to perform services on our behalf (such as when you enquire about one of our initiatives). In doing so, your data may be stored or otherwise processed outside of the EEA. Whenever we transfer your personal data out of the EEA, we ensure the utmost protection is afforded to it.





We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those volunteers, employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 


We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.







We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.


In some circumstances, you can ask us to delete your data. 


In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.





Under certain circumstances, you have rights under data protection laws in relation to your personal data. 


Dependent on the rules of your country, you have the right to:


Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.


Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.


Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.


Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms. 


Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.


Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.


Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


If you wish to exercise any of the rights set out above, please contact us. 





You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.





We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.





We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.







Below are the categories of personal information about California consumers that we collect and disclose for a business purpose. We do not sell personal information.  


We collect and disclose for a business purpose the following categories of personal information:


– Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.


– Usage Data, including the internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.




The categories of sources of personal information we collect are described in the section How Is Your Personal Information Collected above.





We collect the personal information identified above to communicate with you, for advertising and marketing purposes, to provide and improve our services, and other purposes set forth in How We Use Your Personal Information above.





We share personal information identified above with the following categories of third parties:


– Our educational partners,


– Third-party providers that serve business, professional or technical support functions,


– Potential employers (as directed by you), or


– Third parties for legal matters or safety purposes.




California law gives California consumers the right to make the following requests:


– The right to opt-out of the sale of your personal information.  We do not sell personal information.


– The right to request a copy of the personal information that we have collected about you in the prior 12 months.  


– The right to request the deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging, or to comply with a legal obligation).


– The right to request more details about the personal information we collect and how and why we use and share it, including the categories of personal information we have collected about you, the categories of sources for the personal information we collect, the business or commercial purposes for collecting personal information, and the categories of third parties with which we share personal information.


You can submit a copy, deletion, or right-to-know request online by emailing [email protected].


The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data. 


Please note that third parties may, however, collect personal information about your online activities over time and across different websites when you visit our Site or use the Service.