Cookies Policy

GIVELY

GivelyCF Cookies Policy

Proposed website policy · Canada-first platform

Cookies at a glance

• Necessary cookies support functions such as sign-in, security, fraud prevention, load balancing, donation flow and consent records.
• Optional cookies must be classified accurately and remain inactive until the applicable consent standard is met.
• Users must be able to accept, reject or adjust optional categories through a Cookie Settings control.
• Withdrawing consent should be as easy as giving it and should take effect without unreasonable delay.
• A current cookie inventory must identify each deployed technology, provider, purpose and duration.

Contents

• 1. Scope
• 2. What cookies and similar technologies are
• 3. Technologies covered
• 4. Why Gively may use these technologies
• 5. Cookie categories
• 6. First-party and third-party technologies
• 7. Consent and choices
• 8. Browser and device controls
• 9. Retention and expiry
• 10. Data collected
• 11. Disclosures and cross-border processing
• 12. Security
• 13. Children and young people
• 14. Changes to this Policy
• 15. Contact
• Schedule A — Cookie register for publication
• Schedule B — Launch requirements
• Schedule C — Authoritative sources and drafting notes

1. Scope

This Cookies Policy explains how Gively Crowdfunding & Digital Finance Inc. (“Gively,” “we,” “us” or “our”) may use cookies and similar technologies on GivelyCF, including www.givelycf.com, and on related websites, applications, dashboards, mobile experiences or services that link to this Policy (collectively, the “Platform”).

Where GivelyDF uses the same account, consent manager or technologies, this Policy should be presented consistently across both services. If GivelyDF deploys a materially different technology stack, it should publish a service-specific cookie register.

This Policy supplements Gively’s Privacy Policy and Terms of Use. The Privacy Policy governs the broader collection, use, disclosure, retention and safeguarding of personal information.

2. What cookies and similar technologies are

A cookie is a small data file that a website asks a browser or device to store or access. Cookies can recognize a browser, remember a session or preference, support security controls, measure use or enable selected integrations.

Some cookies are removed when the browser session ends. Others remain until their stated expiry, until the user deletes them, or until the technology is withdrawn. Similar technologies may operate differently but can serve comparable purposes.

3. Technologies covered

This Policy applies not only to conventional browser cookies but also, where deployed, to local storage, software development kits, pixels, tags, scripts, device identifiers, web beacons and comparable technologies.

Gively will not describe a technology as a cookie merely to avoid explaining a materially different tracking method. Any technology capable of identification, localization or profiling must be evaluated and disclosed according to its actual function and applicable law.

4. Why Gively may use these technologies

• Operate pages, accounts, authentication and user sessions.
• Secure the platform, detect abuse and support fraud or transaction-risk controls.
• Remember language, accessibility, region and other choices.
• Support donation, campaign, subscription, receipt and GLT-related user journeys.
• Understand whether pages and features function as intended.
• Measure performance and improve navigation, content and service design.
• Deliver personalization, integrations or communications selected by the user.
• Measure campaigns or advertising only where deployed and lawfully authorized.

5. Cookie categories

The categories below describe permitted purposes. A technology must be classified according to what it actually does, not according to its name or vendor. A multi-purpose technology must not be placed in a less protective category merely because one of its functions is necessary.

Sensitive contexts

Donation history, charitable interests, personal-cause activity and campaign interactions can reveal or permit inferences about health, religion, political opinions, hardship or other sensitive matters. Gively should not use such information for cross-context behavioural advertising or create advertising audiences from it. Any exceptional use requires a documented necessity, proportionality and legal assessment and, where permitted, appropriate express consent.

6. First-party and third-party technologies

First-party technologies are set or controlled by Gively. Third-party technologies are provided or controlled by another organization, such as an identity, payment, security, analytics, video, social-media, customer-support or advertising provider.

Gively must identify deployed third parties in Schedule A or in the live Cookie Settings interface. Each provider may process information under its own terms and privacy notice. Gively will assess providers and contractual protections before deployment but cannot control an independent provider’s separate websites or services.

A provider must not be presented as active, integrated or approved unless that statement is operationally true.

7. Consent and choices

When consent is required, Gively will request it before activating the relevant optional technology. The request should be prominent, understandable and separate from unrelated terms. Refusing optional technologies should be as easy as accepting them.

The consent interface should provide Accept All, Reject Optional and Customize choices of comparable prominence. Pre-ticked boxes, inactivity, continued browsing alone or design that steers users toward acceptance should not be relied upon as valid consent where a positive choice is required.

A Cookie Settings link should remain available from the website footer or equivalent persistent location. Changes should apply without unreasonable delay and be recorded for accountability. A user may need to repeat a choice if cookies are cleared, a different browser or device is used, or the consent record expires.

Necessary technologies may operate without an optional-cookie election where they are reasonably required for the requested service or permitted by law. This does not permit Gively to label optional analytics or advertising as necessary.

Québec users and identification, localization or profiling

Where Québec’s Act respecting the protection of personal information in the private sector applies, Gively will provide the notice and choice required before using a technology that includes functions permitting a person to be identified or located or permitting profiling. Such functions will not be activated by default where the law requires the individual to activate them.

Gively’s final banner and Cookie Settings interface must be validated against the actual technologies deployed. This section does not represent that any profiling, localization or advertising technology is currently in use.

8. Browser and device controls

Most browsers allow users to view, block or delete cookies. Device or operating-system settings may offer additional controls. Blocking all cookies can prevent sign-in, donation processing, consent remembrance or other core functions.

Browser privacy signals, including Global Privacy Control or Do Not Track, are not implemented uniformly. Gively should document which signals its systems recognize and update this section before publication. Where applicable law requires recognition of a signal, Gively will honour it.

9. Retention and expiry

Each cookie or similar technology must have a duration proportionate to its purpose. Session technologies should expire when the session ends unless a longer period is necessary. Persistent technologies must not be retained indefinitely by default.

The live cookie register should disclose the stated duration of each deployed technology. Gively will periodically review cookies and consent records and remove or shorten technologies that are no longer necessary.

10. Data collected

Depending on the technology and the user’s choices, technical data may include browser or device type, operating system, language, approximate location derived from IP address, IP address, referral page, pages viewed, timestamps, session identifiers, feature interactions, error records, campaign attribution and consent status.

Gively must not state that this data is anonymous unless re-identification is not reasonably possible. Pseudonymous identifiers may still constitute personal information.

Payment-card details, government identifiers, passwords and the contents of private donation or verification documents should not be placed in analytics or advertising tools.

11. Disclosures and cross-border processing

Information generated through these technologies may be handled by Gively and approved service providers that support hosting, security, payment flows, identity verification, analytics, communications or other disclosed functions.

Providers may process information outside the user’s province or country, where it may be subject to foreign laws and lawful access. The final policy must identify material processing locations or provide accurate criteria consistent with Gively’s validated vendor and data map.

Recipient charities and organizers should not receive cookie-level data unless it is necessary, appropriately disclosed and supported by the required authority or consent. Aggregated campaign reporting should be preferred where individual-level data is unnecessary.

12. Security

Gively will apply safeguards appropriate to the sensitivity and purpose of information generated through cookies and similar technologies. Access should be limited, vendor permissions minimized, and tags governed through change control.

No internet or storage system is completely secure. Users should contact Gively promptly if they believe a cookie, account or session has been compromised.

13. Children and young people

Gively’s final age and organizer-eligibility rules must be confirmed in the Terms and Privacy Policy. Gively should not knowingly use optional behavioural advertising or profiling technologies to track children or on services directed to children.

If Gively learns that an optional technology collected a child’s personal information without valid authority, it should disable the use and take reasonable steps to delete or de-identify the information, subject to legal retention requirements.

14. Changes to this Policy

Gively may update this Policy when its services, technologies, providers or legal obligations change. The effective date and version should be updated, and material changes should be communicated through an appropriate notice. New optional technologies should not be activated under a materially expanded purpose without obtaining any consent required by law.

Continued browsing or use of the Platform alone will not be treated as consent to a new optional-cookie purpose where a positive choice is required.

15. Contact

Questions, complaints or requests concerning cookies or personal information may be directed to: