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Privacy Policy

  1. Updated November 3, 2026
  2. Effective December 1, 2026


This Privacy Policy for Bonfire Funds, Inc. (doing business as ?Bonfire? and ?Bonfire Pro?) ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • -Visit our website at http://www.bonfire.com (the ?Website?) or any other website or online platform of ours that links to this Privacy Policy
  • - Engage with us in other related ways, including sales, marketing, events, or other points of collection where this Privacy Policy is posted


Questions or concerns? Reading this Privacy Policy 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 [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process information that is linked or reasonably linkable to an identified or identifiable natural person (?personal information?). The personal information we may process depends on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us in the ?WHAT INFORMATION DO WE COLLECT? section below.

Do we process any sensitive personal information? What personal information is considered ?sensitive? personal information differs by relevant law. We may process certain sensitive personal information as described in this Privacy Policy when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process in the ?WHAT INFORMATION DO WE COLLECT? section below.

Do we collect any information from third parties? We may receive personal information from third parties, including through social media logins (such as Facebook or Google), cookies and similar tracking technologies operated by third parties, and other sources as described in the ?WHAT INFORMATION DO WE COLLECT? section below.

How do we process your information? We process your personal information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with applicable laws. We may also process your personal information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information in the ?HOW DO WE PROCESS YOUR INFORMATION?? section below.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information in the WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? section below.

How do we keep your information safe? We have 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. Learn more about how we keep your information safe in the HOW DO WE KEEP YOUR INFORMATION SAFE? section below.

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. Learn more about your privacy rights in the WHAT ARE YOUR PRIVACY RIGHTS? section below.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://www.bonfire.com/dsar/, or by contacting us. We will consider and act upon any request in accordance with applicable data protection and privacy laws.

Want to learn more about what we do with any information we collect? Review the below Privacy Policy in full.

TABLE OF CONTENTS

SUMMARY OF KEY POINTS

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 INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. DO WE OFFER ARTIFICIAL INTELLIGENCE BASED PRODUCTS?

8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

9. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

10. HOW LONG DO WE KEEP YOUR INFORMATION?

11. HOW DO WE KEEP YOUR INFORMATION SAFE?

12. DO WE COLLECT INFORMATION FROM MINORS?

13. WHAT ARE YOUR PRIVACY RIGHTS?

14. CONTROLS FOR DO-NOT-TRACK FEATURES

15. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

16. DO WE MAKE UPDATES TO THIS NOTICE?

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose To Us

We collect personal information that you voluntarily provide to us when you register on the Services, 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
  • - email addresses
  • - mailing addresses
  • - usernames
  • - passwords
  • - contact preferences
  • - contact or authentication data
  • - billing addresses
  • - phone numbers
  • - job titles
  • - debit/credit card numbers
  • - payout preferences
  • - bank information
  • - fundraiser information
  • - job applicant information


Sensitive Personal Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following information that may be considered ?sensitive? personal information under applicable laws:

  • - social security numbers or other government identifiers
  • - information revealing political opinions
  • - certain financial and payment data


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 our third party payment processors. You may find their Privacy Policy link(s) here:


Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

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

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. You can find out more about this in the section "DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?" below.

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. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

  • Location Data. We collect location data such as information about your device's location based on your IP address. How much information we collect depends on the type and settings of the device you use to access the Services. 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. However, if you choose to opt out, you may not be able to use certain aspects of the Services.


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?

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

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

  • 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 request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.

  • To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: https://app.termly.io/policy-viewer/policy.html?policyUUID=2712b9d2-7f2f-4b3b-8662-738dd6738209.

  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

  • 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.

  • To prevent fraud. We may process your information to identify fraudulent activity and financial purchases

  • Account verification. We may process information to confirm your account connections, such as confirming you are the owner of an Instagram account or confirming that you are associated with a nonprofit that you apply to be a member of.

  • To facilitate business transactions. We may process 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.


3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

If you are located in the EU or UK, this section applies to you.
When we process your personal information, we may rely on the following legal bases:

  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent in the ?WHAT ARE YOUR PRIVACY RIGHTS?? section.

  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • - Send users information about special offers and discounts on our products and services
    • - Develop and display personalized and relevant advertising content for our users
    • - Analyze how our Services are used so we can improve them to engage and retain users
    • - Support our marketing activities
    • - Diagnose problems and/or prevent fraudulent activities
    • - Understand how our users use our products and services so we can improve user experience
    • - Verify the identity of our users

  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

  • 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, such as situations involving potential threats to the safety of any person.


In legal terms, we are generally the ?data controller? under data protection laws of the personal information described in this Privacy Policy, since we determine the means and/or purposes of the data processing we perform. This Privacy Policy does not apply to the personal information we process as a ?data processor? on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the ?data controller? responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers? privacy practices, you should read their privacy policies and direct any questions you have to them.

If you are located in Canada, this section applies to you.
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. Learn more about withdrawing your consent in the ?WHAT ARE YOUR PRIVACY RIGHTS?? section.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • - If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

  • - For investigations and fraud detection and prevention

  • - For business transactions provided certain conditions are met

  • - If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

  • - For identifying injured, ill, or deceased persons and communicating with next of kin

  • - If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

  • - If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

  • - If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

  • - If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

  • - If the collection is solely for journalistic, artistic, or literary purposes

  • - If the information is publicly available and is specified by the regulations

  • - We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments.


4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Vendors, Consultants, and Other Third-Party Service Providers.
We may share your personal information with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work, subject to our agreements with such third parties and any provisions therein designed to help safeguard your personal information.

The categories of third parties we may share personal information with are as follows:

  • - Ad Networks
  • - AI Platforms
  • - Cloud Computing Services
  • - Communication & Collaboration Tools
  • - Data Analytics Services
  • - Data Storage Service Providers
  • - Finance & Accounting Tools
  • - Government Entities
  • - Order Fulfillment Service Providers
  • - Payment Processors
  • - Performance Monitoring Tools
  • - Product Engineering & Design Tools
  • - Retargeting Platforms
  • - Sales & Marketing Tools
  • - Social Networks
  • - Testing Tools
  • - User Account Registration & Authentication Services
  • - Website Hosting Service Providers


We also may need to share your personal information in the following situations:

  • 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.

  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

  • Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.


Sharing of Information with Campaign Creators and Benefitting Nonprofits.
Buyer?s personal information is shared with sellers and, for Giving Campaigns, the benefitting nonprofit. Sellers (and the benefitting nonprofit, if applicable) will have access to the buyer?s name, email address, mailing address, phone number, employer and occupation, depending on whether that information was entered at checkout. No seller will have access to billing addresses or credit card information of any buyers. If you are located in the EU or Canada, you may choose not to share your information with the seller or benefitting nonprofit.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

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 and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://app.termly.io/policy-viewer/policy.html?policyUUID=2712b9d2-7f2f-4b3b-8662-738dd6738209.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Remarketing with Google Analytics, Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

7. DO WE OFFER ARTIFICIAL INTELLIGENCE BASED PRODUCTS?

As part of our services, we offer and/or use products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, ?AI Products?). These tools are designed to enhance your experience and provide you with Innovative solutions. All personal information processed using our AI Products is handled in line with our Privacy Policy and our agreement with third parties.

8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their Privacy Policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

9. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in the United States, and other countries.

10. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

11. HOW DO WE KEEP YOUR INFORMATION SAFE?

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, 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. Thus, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

12. DO WE COLLECT INFORMATION FROM MINORS?

Bonfire does not knowingly collect or maintain personal information, solicit data, or market to children under eighteen (18) years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least eighteen (18). If we learn that personal information from users less than eighteen (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 eighteen (18), please contact us at [email protected].

13. WHAT ARE YOUR PRIVACY RIGHTS?

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. In certain circumstances, you may also have the right to object to the processing of your personal information. If you are a resident of the United States, you may have additional rights as further outlined in the ?DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?? section below. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

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, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, changing your communication preferences within your account settings, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you ? for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Your mobile phone number will not be shared with third parties or affiliates for their marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties. Note that this restriction applies specifically to your phone number and text messaging consent data; other mobile device information (such as device identifiers) may be shared as described elsewhere in this Privacy Policy.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • - Contact us using the contact information provided.
  • - Log in to your account settings and update your user account.
  • - Visit https://cap.bonfire.com/user-deletion to delete your account and information (you must be logged in).


Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

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 choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Notice: https://app.termly.io/policy-viewer/policy.html?policyUUID=2712b9d2-7f2f-4b3b-8662-738dd6738209.

If you have questions or comments about your privacy rights, you may email us at [email protected].

14. 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. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

However, unlike DNT signals, we do recognize and respond to Global Privacy Control (?GPC?) signals. GPC is a browser setting that allows you to signal your privacy preferences to websites you visit. When you enable GPC, your browser sends a signal to websites requesting that your personal information not be sold or shared for targeted advertising purposes. Under certain U.S. state privacy laws, including the California Consumer Privacy Act (as amended by the CPRA), we are required to treat GPC signals as valid opt-out requests. You can learn more about GPC and how to enable it by visiting the Global Privacy Control website at https://globalprivacycontrol.org/.

15. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYES
B. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial informationYES
C. Protected classification characteristics under state or federal lawGender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic dataNO
D. Commercial informationTransaction information, purchase history, financial details, and payment informationYES
E. Biometric informationFingerprints and voiceprintsNO
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisementsYES
G. Geolocation dataDevice locationYES
H. Audio, electronic, sensory, or similar informationImages and audio, video or call recordings created in connection with our business activitiesYES
I. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usYES
J. Education InformationStudent records and directory informationNO
K. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual?s preferences and characteristicsYES
L. Sensitive personal InformationAccount login information, debit or credit card numbers, financial information including account access details, social security numbers and citizenship or immigration statusYES


We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Your acceptance of this Privacy Policy and continued use of the Services includes your explicit consent to our processing of your sensitive personal information as described in this Privacy Policy. If you do not consent to the use of your sensitive personal information as described herein, do not provide any sensitive personal information to us or use the Services.

Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • - Receiving help through our customer support channels;
  • - Participation in customer surveys or contests; and
  • - Facilitation in the delivery of our Services and to respond to your inquiries.


We use and retain the personal information we collect as long as we have a valid reason to keep the data.

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

We collect and share your personal information through:

  • - Targeting cookies/Marketing cookies
  • - Social media cookies
  • - Beacons/Pixels/Tags
  • - Social media plugins: Facebook Login operated by Facebook, Inc. and Sign In with Google operated by Google, Inc. 

We use social media features, such as a "Like" button, and widgets, such as a "Share" button, in our Services. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Services. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policies of the companies that provide them. By clicking on one of these buttons, you agree to the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers or other third parties as described in this policy.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. We do not sell your personal information for monetary consideration. However, we may process your personal information for purposes of targeted advertising or profiling. Under certain U.S. laws, such activities may be considered a ?sale,? and you may have rights regarding opting-out of the processing of your personal information for these purposes as described herein.

We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

  • - Category A. Identifiers
  • - Category B. Personal information as defined in the California Customer Records law
  • - Category D. Commercial information
  • - Category F. Internet or other electronic network activity information
  • - Category G. Geolocation data
  • - Category H. Audio, electronic, visual, and similar information
  • - Category I. Professional or employment-related information
  • - Category K. Inferences drawn from collected personal information
  • - Category L. Sensitive personal information


The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

As mentioned above, while we do not ?sell? personal information for monetary consideration, we have shared the following categories of personal information to third parties in the preceding twelve (12) months, including for the above purposes (including targeted advertising and profiling) which may be considered a ?sale? under applicable law:

  • - Category A. Identifiers
  • - Category B. Personal information as defined in the California Customer Records law
  • - Category D. Commercial information
  • - Category F. Internet or other electronic network activity information
  • - Category G. Geolocation data
  • - Category K. Inferences drawn from collected personal information


As mentioned above, while we do not ?sell? personal information for monetary consideration, we have shared personal information to the following categories of third parties:

  • - Ad Networks
  • - AI Platforms
  • - Social Networks
  • - Retargeting Platforms
  • - Data Analytics Services
  • - User Account Registration & Authentication Services


Your Rights

  • - Applicable Privacy Laws may provide you with specific rights regarding your personal data. This section describes your rights and explains how to exercise those rights. Certain requirements must be met for consumers to exercise their rights, see ?How to Exercise Your Rights? below for more information. Some of the activities may be considered ?sales? or ?sharing? of your personal data or ?targeted advertising? under applicable Privacy Laws. Depending on where you reside, you may have the right to opt out of targeted advertising, sharing, and/or the sale of your personal data. These rights are not absolute, and in certain cases, we may decline your request as permitted by law.

  • - You may opt out of the sale/sharing of your personal data by clicking the ?Your Privacy Choices? link (also found at the bottom of the page), or you may broadcast the Global Privacy Control signal through your web browser or device. More information on Global Privacy Controls can be found at https://globalprivacycontrol.org/. If neither of these options work for you, you may also email us at the email listed in the ?HOW CAN YOU CONTACT US ABOUT THIS NOTICE?? section below.

  • - We do not use your personal data to profile in furtherance of decisions that produce legal or similarly significant effects as defined under applicable Privacy Laws.

  • - Under certain applicable Privacy Laws, you have the right to request that we disclose certain information to you about our collection and use of your personal data, including: the categories of personal data we collected about you; the categories of sources for the personal data; our business or commercial purpose for collecting or selling that personal data; the categories of third parties with whom we share that personal data; and to receive the specific pieces of personal data we collected about you in a portable and, to the extent technically feasible, readily usable format.

  • - Under certain applicable Privacy Laws, you have the right to request that we correct inaccurate personal data that we collected from you and retained, taking into account the nature of the personal data and the purposes of processing personal data. Once we receive and confirm your consumer request, we will use commercially reasonable efforts to correct the inaccurate personal data.

  • - Under certain applicable Privacy Laws, you have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your consumer request, we will delete (and where required by applicable law, direct our service providers to delete) your personal data from our records, unless an exception applies.


How to Exercise Your Rights

Only you, or someone legally authorized to act on your behalf, may make a ?verifiable consumer request? related to your personal data. Please submit a consumer request by visiting https://www.bonfire.com/dsar/, by calling us toll-free at 1-855-537-2613, or emailing us at [email protected].

To be verifiable, a consumer request must: (a) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data and that you have rights under applicable Privacy Laws; (b) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it; and (c) if applicable, provide sufficient information that allows us to reasonably identify you are an authorized representative of the person whom we collect personal data about.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a consumer request does not require you to create an account with us, but we may require authentication of the person requesting the data that is reasonable in light of the nature of the personal data requested.

Request Verification

Once received, we will respond to your request within the timeframe required by applicable law. If additional time is permitted and needed, we will notify you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, to the extent technically feasible.

We do not charge a fee to process or respond to your consumer request unless it is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your consumer request.

Appeals

Under certain Privacy Laws, you may have a right to appeal our decision regarding your initial consumer request. If you have a right to appeal, your appeal should be sent to the place where the initial consumer request was sent (see How to Exercise Your Rights above). The appeal should clearly indicate that it is an appeal of an initial consumer request and should include the initial request along with our response explaining why we cannot comply with the request. We will answer your request within a reasonable time frame. Once we respond, we will inform you of any action taken or not along with an explanation of the reason in support of the response. If you have any concerns about the results of an appeal, you may have the right to be notified under applicable Privacy Laws that you can submit a complaint to your attorney general.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under Privacy Laws. Unless permitted by Privacy Laws, we will not: deny goods or services; charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

16. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, 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 Policy frequently to be informed of how we are protecting your information.

17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

Bonfire Funds, Inc.
1400 W. Lombard St, Ste A - Unit 2051
Baltimore, Maryland 21223
United States

Based on the applicable laws of your country, region, 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 exercise these rights or to submit a request, please contact us at [email protected] or visit: https://www.bonfire.com/dsar/.

If you are located in the EU or UK, this section applies to you.
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group, with its local partners, as our privacy representative and your point of contact for UK and EU regions. If you would like to contact us via our representative or review the representative information, please click here: https://app.prighter.com/portal/19720579228.