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Last updated: 13 May 2025

1. Who We Are

Project Wellspring (“PW,” “we,” “our,” or “us”) is a U.S. social‑impact organization that accelerates inclusive wealth creation. We operate https://www.projectwellspring.com and related sub‑domains (collectively, the “Site”) and, through fiscal‑sponsorship arrangements and partnerships with independent Registered Investment Advisers (“RIAs”) and wealth‑advisory firms, provide charitable asset‑management services.

 

2. Scope

This Privacy Policy (“Policy”) explains how we collect, use, disclose, and secure Personal Information when you:

• visit or use the Site;

• donate, open, or recommend a donor‑advised fund (“DAF”) or other charitable account;

• apply for, invest in, or receive capital through PW programs; or

• otherwise interact with us online or offline.

It also describes your privacy rights under applicable laws, including (where relevant) the EU/UK General Data Protection Regulation (“GDPR”) and U.S. state privacy statutes such as the California Privacy Rights Act (“CPRA”), Colorado Privacy Act, Virginia Consumer Data Protection Act, and other similar state laws.

 

3. Information We Collect

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4. How We Use Personal Information

We use Personal Information to:

1. Provide and administer our services—for example, opening and servicing DAFs, processing contributions, facilitating grants or impact investments, and issuing tax receipts.

2. Work with fiscal sponsors and independent RIAs/wealth‑advisory partners to execute asset‑allocation, impact‑screening, or other instructions you authorize.

3. Comply with legal obligations (e.g., anti‑money‑laundering rules, donor‑advised‑fund regulations, IRS reporting).

4. Analyze, secure, and improve the Site and our programs.

5. Communicate with you about program updates, impact reports, and marketing (with your consent).

6. Conduct research and impact measurement in anonymized or aggregated form.

 

5. Legal Bases (GDPR)

Where GDPR applies, our processing relies on one or more of the following bases: (i) contract performance, (ii) legitimate interests (such as fraud prevention and impact measurement), (iii) compliance with legal obligations, and (iv) consent, where required.

 

6. Sharing & Disclosures

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7. Cookies & Similar Technologies

The Site uses:

• Essential cookies required for core functionality;

• Analytics cookies (e.g., Google Analytics) to understand usage patterns; and

• Advertising or social‑media cookies (only with your consent) to deliver relevant messaging.

You can manage cookies via our cookie banner or through your browser/device settings. Blocking some cookies may affect Site performance.

 

8. Security

We employ industry‑standard administrative, technical, and physical safeguards, including encryption in transit and at rest, access controls, periodic security reviews, and vendor due‑diligence requirements.

 

9. Data Retention

We retain Personal Information only as long as necessary for the purposes described above and to meet legal, accounting, or archival requirements (typically seven years for charitable gift records).

 

10. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

• Access, correct, or delete Personal Information;

• Receive an electronic copy (data portability);

• Opt‑out of “sale,” “sharing,” or targeted advertising (where applicable);

• Limit use of sensitive data;

• Withdraw consent at any time (where processing is based on consent);

• Be free from discrimination for exercising privacy rights.

To exercise any of these rights, contact us at info@projectwellspring.com or +1‑800‑PW‑PRIV. We will verify your identity before fulfilling requests.

 

11. International Transfers

The Site is hosted in the United States. If you are located outside the U.S., your information may be transferred to, processed, and stored in the U.S. We rely on Standard Contractual Clauses or other appropriate safeguards for such transfers.

 

12. Changes to This Policy

We may update this Policy from time to time. We will post the revised version on the Site and update the “Last updated” date. Continued use of the Site after changes become effective constitutes acceptance of the revised Policy.

 

13. Contact Us

For questions or concerns about this Policy or our data practices, please e‑mail info@projectwellspring.com.