Privacy Policy Last Updated: May 21, 2024
The Bungie Foundation respects the privacy interests and preferences of our donors, fundraisers, and website visitors (https://www.bungiefoundation.org). We are committed to full transparency. This Privacy Policy explains when we collect information about you, including Personal Information (“PI”), what we collect, why we collect it, how we use it, who we share it with, where it is processed, how we handle it, and your choices and legal rights associated with this information.
Scope of this Policy
The Bungie Foundation (“Bungie,” “we,” “our,” “us”) controls the information collected when you interact with our BungieFoundation.org website and associated services (the “Website”).
Contact Us
If you have any questions or comments regarding this Privacy Policy or require additional information, please contact us:
By email: bngfoundation@bungie.com
By mail:
Privacy Requests Bungie Foundation 550 106th Avenue NE Suite 108 Bellevue, WA 98004-5088
If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at bngfoundation@bungie.com.
What data we collect about you When you make a donation, purchase a product, express an interest in supporting the Bungie Foundation, or subscribe to our online newsletter, the Bungie Foundation asks you for personal contact information such as your name, mailing address, phone number and e-mail address. We may use this contact information to provide you with a receipt or financial report, to contact you to clarify or obtain additional information about an order you placed, a donation you made, or to send you additional information about the Bungie Foundation. If you make a donation, you may be contacted by us on occasion to offer you an opportunity to make another gift to our organization or one of our partner organizations. You may also receive a personal email from a Bungie Foundation staff member or volunteer thanking you for your donation. However, as a matter of long-standing policy we do not use third party telemarketers or other outside vendors to solicit funds or otherwise communicate with our donors on our behalf. You will always have the opportunity to opt-out of future communications from us. Personal contact information may also be shared with certain vendors (i.e., reputable companies we use for services such as shipping Bungie Foundation swag, merchandise, or mail). We have confidentiality agreements in place with all such companies to protect your privacy.
Information You Provide to Us
We collect the information that you directly provide to us, such as when you enter it on our website, or include it in an email that you send to us. This type of collection often occurs through our business support processes, such as:
• Contact Data, including your first and last name, email address, postal address, and phone number.
• Transaction Data, including your billing or shipping address, and donation/purchase history. Your payment information, such as credit card details, are managed through third party suppliers, including, but not limited to Stripe and PayPal. Payment information is subject to the privacy policies of these third party suppliers. For the purpose of processing payments, the Bungie Foundation only works with third party suppliers who encrypt data being collected. Please see their websites for more information.
• Content, including content within any messages you send to us (such as feedback and questions to support).
We may also collect information from you at various points through the Website, including as follows:
• Subscriptions and Promotions. Should you choose to subscribe to our newsletters or enter a promotion, you may provide your contact data or other information.
• Community Interaction. If you post any information to the Website communities, forums, messaging functionality, or social or interactive features, we may collect such information.
• Customer Service. When you contact our customer service, we may collect your contact data, profile data, as well as content and any other information you choose to provide to us.
• Feedback. If you provide feedback through one of our feedback polls, we collect any responses to our poll-specific questions, content you may provide in the open-text field of the poll (if applicable), as well as device data and imprecise location data (discussed in more detail below) at the time the feedback is submitted.
Automatic Information Collection
We may also automatically or passively collect information about your use of our Website; see the sub-sections below for a list of categories by sources of such information.
• Cookies, Pixels and Similar technologies. When you visit our website, we might store some information on your computer in the form of a “cookie” (which is a small piece of data that stores information on your browser in your computer’s hard drive) or similar file. We use conversion tracking cookies for campaigns, which analyze trends, gather broad demographic information and monitor website traffic patterns that can help us further develop and improve the design and functionality of our site.
• Usage Data, including information about your use of the Website, the pages and content that you view, the referring and exiting pages, your access times, the links you click, and other actions taken within the Website.
• Device Data, including your device type, operating system type, browser type, device regional and language settings, IP address, and device ID (such as IDFA or AAID).
• Location Data, for example based on your IP address or data that indicates you current or recent locations.
For information on how you can control automatic collection and your rights, use the cookie banner on our website or see the “Your Rights and Choices” sections below.
Personal Information Obtained from Other Sources.
We may also receive information from other sources including:
• Vendors and Ad Partners. Under some circumstances we may collect information from vendors and ad partners in connection with advertising and analytics-related services.
• Social Networks. We collect information when if you engage with our content, or reference us on a social network (e.g., Twitch, YouTube). In most cases this is aggregate and does not identify you or any individual users. We may also receive some of your account or profile information if you choose to link or sign in with your social network account, or grant us permission to access information from the social networks.
• Publicly Available Sources. We collect information from the public domain.
Use of Information.
We may collect and use Personal Information as described below, including:
• Contract – to provide services to you and fulfill our contractual relationship with you. For example, when you make a donation on our website, we leverage third party suppliers to process your payment. If applicable, Bungie Foundation staff will communicate with you, respond to your inquiries, and grant rewards that are owed to you;
• Legitimate Interests – to fulfill our legitimate interests, or those of a third party in conducting and managing our business and our relationship with you as described in this Privacy Policy. For example, we rely on legitimate interest to (a) detect and prevent fraud, the unauthorized use of our Website, and other harmful or illegal activity, (b) improve our services, including by performing analytics and business reporting in relation to how you use our Website and any issues you may encounter, and (c) share information with other affiliated companies where necessary to support the security of our Website.
• Legal obligation - to meet our legal obligations under applicable law, including to comply with financial reporting requirements.
• Consent – where you have provided us consent to process your PI for a specific purpose. including to send marketing messages and personalized advertisements to you. When we process your PI on the basis of consent, you can withdraw your consent at any time.
• We may combine information from any of the sources explained in the “Information That We Collect or Receive” section of this Privacy Policy. For example, we may process together information we have collected from you from your visits to our website for the purposes explained in this Privacy Policy.
For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
Disclosure of Information
Depending on the way you interact with us, we may share the Personal Information we collect about you in as described in this Section:
• Bungie Foundation. We share information with our affiliates and subsidiaries.
• Service Providers. We share information with other companies that provide services to us or on our behalf, such as sending communications, processing payments, fulfilling transactions, answering questions, providing technical support, hosting our websites, enabling data analytics, and similar functional or operational purposes. The Personal Information they have access to is limited to what is needed to deliver the service.
• Ad Partners. We may share your information with ad partners in connection with advertising and analytics-related services if you are of a certain age and consistent with applicable law.
• Security and Compelled Disclosure. We share information to (a) comply with legal process served on us, or our suppliers, and otherwise when we have a good faith belief that doing so is required by law; (b) protect and defend our rights or property or those of our suppliers; (c) protect the personal safety of our employees or agents, users of Website, or members of the public, or (d) protect the integrity of the online community on the Website. At its discretion and consistent with applicable laws, we will provide such information to law enforcement upon reasonable request directed to bngfoundation@bungie.com and does not require subpoena.
• Merger or Acquisition. We may share information as part of any merger, acquisition, or sale of company assets, as well as in the unlikely event of an insolvency, bankruptcy or receivership in which information would be transferred.
• Facilitating Requests. We share information at your request or direction, such as when you choose to share information with a social network about your activities on the Website.
• Consent. We share information with notice to you and your consent.
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
Other Services.
We offer elements of our Website through websites, platforms, and services operated or controlled by separate entities. In addition, we integrate links and technologies operated or controlled by separate entities into parts of the Website. Please note that when you interact with other entities, including when you leave the Website, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
You may have certain rights and choices about how your information is collected, used, stored, and shared depending on your age or where you live. Most of these options can be accessed by Contacting Us through the methods provided.
• Request to Access and Correct: You have the right to request that we inform you of the Personal Information we hold about you, as well as to request the correction of any inaccurate information about you.
• Right of Access: You have the right to request that we inform you of the Personal Information we have collected, used and shared about you, and to obtain a copy of it.
• Right of Deletion: You have the right to request that we delete the Personal Information we have collected or retained about you in some circumstances as defined by law. Following your request for deletion, please be aware that the information that we collect about you may still be retained for legal, accounting, business continuity (backup), anti-fraud, security, and community reasons.
In some cases, your choices to provide, change or delete information may affect our ability to deliver services, or your user experience. We may decline to process requests which will impact our ability to secure the Website, enforce or defend our legal rights, or that are not otherwise required by applicable law. You have the right not to be unlawfully discriminated against because you have exercised these rights.
Authorized Agent
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
Right to Opt-Out of Sell or Share or Targeted Advertising or Limit Processing
The Bungie Foundation never shares your information with third parties to provide ads or recommendations that are more personalized to you. This eliminates the need to opt-out of targeted advertising.
If you have questions or concerns, email us at bngfoundation@bungie.com.
“Do Not Track”
We do not process or respond to web browser “Do Not Track” signals or other similar transmissions that indicate a request to disable online tracking of users who use or visit the Website. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Security
We implement technical and organizational measures designed to ensure a level of security appropriate to the risk. We use a variety of security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. For example, we store the information you provide on computer servers with access restrictions that are located in controlled facilities.
Data Retention
We take measures to delete your information or aggregate or de-identify your information when it is no longer necessary for the purposes for which we collected it, unless we are required to keep this information for a longer period in accordance with this Privacy Policy or our retention of it is otherwise justified by this Privacy Policy or applicable law. When determining the retention period, we take into account various criteria, such as maintaining access to products you have purchased, the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law, and the statute of limitations.
International Data Transfers
Our Website is operated in the United States and other countries/areas/regions around the world. Please be aware that information we collect, including PI, will be transferred to, processed and stored in these countries/areas/regions and, as such, courts, law enforcement, and other authorities in these countries may, in certain circumstances, be entitled to access your PI. We ensure there are adequate safeguards in place when transferring your information outside your country by entering contracts with the recipients, European Commission Standard Contractual Clauses or otherwise that the transfer only occurs where permitted by applicable law. By using our Website or providing us with any information through them, you acknowledge this transfer, processing, and storage of your information in these countries in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.
Children’s Privacy
The Bungie Foundation does not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children under 13 years of age in a manner not permitted by COPPA. If we learn that personal information of a child under the age of 13 years has been collected on the Website without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or legal guardian and discover that your child under the age of 13 has provided personal information to us, please contact us as set out in the “Contact Us” section below and request that we delete that child’s personal information.
Changes to this Privacy Policy
We may occasionally update this Privacy Policy. When we do, we will also revise the “last updated” date at the top of the Privacy Policy. For material changes to this Privacy Policy, we will notify you by placing prominent notice on the Website and may provide you additional notice to your email address. We encourage you to periodically review this Privacy Policy to be informed of how we are collecting, using, and disclosing your information.