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Privacy Policy & Terms of Use

Privacy Policy

Havasu Freedom Foundation dba HavasuMemorialWalkway respects your privacy. We collect information to provide services to you, update you on the impact of your contributions, and communicate about promotions or special services. HavasuMemorialWalkway recognizes that we must maintain and use your information responsibly.

Privacy Policy Overview

This policy describes what personal data we collect, how we use it, and your choices.

We collect information from you when you visit and take actions on our website. We use this information to provide the services you’ve requested. We use cookies (such as Google Analytics) to provide a better experience and improve our website and web beacons and similar technologies to track usage patterns.

You can access your data, edit your preferences, download your data, or revoke consent by visiting your account. Except for the purposes outlined below, we will not trade, share, or sell your personal data with anyone. Refer to the policy for complete details.

We have updated our Privacy Policy to take into account the new requirements of the General Data Protection Regulation (“GDPR”). If you are based in the European Economic Area, we will transfer your personal data to the United States pursuant to our Privacy Shield certification.

If you have any questions about our Privacy Policy, please contact us at

LAST MODIFIED: February 20th, 2019

By continuing to access or use (our ‘Website’), you agree to be legally bound by this Privacy Policy and the Terms of Service. These Terms and Supplementary Terms may be modified from time to time and the changes will be posted on our Website.

This policy applies to information collected by the HavasuMemorialWalkway Foundation and any third-party affiliates through all channels, including online and offline donations. is operated by Havasu Freedom Foundation a 501(c)3 organization (EIN: 26-1641208) based in Lake Havasu City, AZ, United States.

For the purposes of the applicable data protection law, including the GDPR, HavasuMemorialWalkway are joint data controllers for the processing of your personal data.

Information Collected from Website Visitors

As a visitor to our Website, HavasuMemorialWalkway’s servers automatically record certain information, such as your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Website), your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Website, which can be used to identify you. We may collect this information also through the use of cookies or other tracking technologies (please read the “Cookies” section below for more information).

You may choose to interact with our Website by entering data into form fields and providing personal data to HavasuMemorialWalkway, such as giving us your name, email address, and password when signing up for an account, filling out an application, making a donation, or creating an account to post comments on pages, projects, or our blog.

We only collect personal data that is reasonable or necessary to accomplish the purpose of your interaction with HavasuMemorialWalkway as a visitor to our Website. You may choose not to provide this information, but you need to understand that as a result, you may not be able to engage in certain activities on the Website. Any personal data provided by you as a visitor to the Website will be used only as described in this Privacy Policy.

Information Collected from Registered Users

We collect information when you create an account on our Website, edit your account information, donate to a project, apply to join HavasuMemorialWalkway as an organization, or send or use a gift card, as described below.

Creating an Account:
When you create an account on our Website, we collect basic information about you – your name and email address. You can choose to provide additional information, such as your mailing address, a photo, favorite projects, etc., if you create a profile or create a HavasuMemorialWalkway fundraiser.

Making a Donation:
When you make an online donation on, we collect personal data such as your name, billing address, and email address, if you have not previously provided these details during a prior session. We collect information about your donation, including the project you are donating to and the amount of your donation. We also collect (but do not retain) credit card numbers which are processed by a third-party payment vendor subject to the Payment Card Industry Data Security Standards. If you use PayPal, Apple Pay, or a similar service, their use of your information is based on their terms of service and policies, not ours, so we encourage you to review those policies carefully.

Gift Bricks:
When you give a HavasuMemorialWalkway Gift Brick or donation, we collect payment and contact information from you, as well as the name, email address, and mailing address of your recipient. You may create a personal message to the recipient, which is stored on our servers. Except in the limited circumstances described below, we do not read or use your personal messages.

If you are the recipient of a HavasuMemorialWalkway Gift Card, we collect information from you when you redeem the Card to make a donation. Please note that we may share this information with the individual or entity who gave you the gift card.

Donations in Honor/Memory of Someone:
When you make a donation in honor or memory of a loved one, we collect payment and contact information about you, as well as the name, email address, and mailing address of the recipient. You may create a personal message to the recipient, which is stored on our servers. Except in the limited circumstances described below, we do not read or use your personal messages.

Contests, Promotions, and Surveys:
Periodically, HavasuMemorialWalkway may invite you to participate in contests, take advantage of special promotions, and complete online surveys. If you have created a HavasuMemorialWalkway account or profile, information we collect from these contests, promotions, and surveys may be associated with you personally.

Creating a Fundraiser:
When you create a fundraiser for a project on HavasuMemorialWalkway, we collect information about projects you propose or wish to support. HavasuMemorialWalkway notifies the project leader when a fundraiser is established for their project but does not share your personal data with the project leader or the project. Remember, however, that anything you post on your fundraiser site will be seen by visitors to the Website.

If you donate to a fundraiser, then we will also share your name and the date and amount of your donation with the person who created the fundraiser unless you elect to be anonymous.

Information Obtained From Other Sources

We may obtain information about you from public records and from databases like OFAC when conducting due diligence on nonprofit organization or conducting fraud prevention checks on donations.

Use of Information

HavasuMemorialWalkway uses the personal data that you provide, or we obtain, and the technical information logged by our servers to process your donations, to:

  • Process your donations, contact you regarding any questions related to your donation, gift bricks related to your donation (if applicable). Use of this data is necessary for the performance of the contract between you and us in connection with your donation. If you do not provide the necessary data to us or our payment service provider, we will not be able to process your donation.
  • Comply with our legal obligations.
  • We may from time to time send you updates on how your brick donation or general donation has been used, project appeals, newsletters, events, matching opportunities, information about HavasuMemorialWalkway, and projects we think we think will be of interest to you. We will we will only send you this information by email if you consentto us doing so at the time you provide us with your personal data. You may opt out of receiving such emails by following the instructions contained in each email we send you. You can also unsubscribe from HavasuMemorialWalkway communications by emailing
  • As necessary for certain legitimate interests, which include the following:
    • Notify your friends and family about your donation in their honor if you ask us to;
    • Using the technical information logged by our servers when you visit our Website (described above) to improve your experience on our Website (such as remembering your name, the items in your Cart, or your preferences) and preventing fraudulent activity;
    • If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, we will keep basic data to identify you and prevent further unwanted processing;
    • We may anonymize the information that we collect and use such anonymized data for statistical and market research purposes, including sharing it with affiliates, business partners, and academic researchers;
    • Operate the Website and our business; and
    • Compile aggregate statistics that allow us to understand how visitors or registered users use our Website, and to make improvements in design and content to better serve you.

Disclosure of Personal Data

We will share your personal data with our agents, representatives, service providers and contractors in order to process your gift brick orders and donations, offer you services in connection with our Website, communicate news and information about HavasuMemorialWalkway, provide customer service, mail gift cards, notify the project(s) you elect to support about your donation, claiming Gift Aid from UK government, and complete financial transactions. These service providers are authorized to use your personal data only to the extent necessary to serve these purposes, or as otherwise authorized by this policy. Except for the purposes outlined herein, we will not trade, share, or sell a donor’s personal data with anyone else.

Unless you ask us not to, we share your personal data under the following circumstances:

  • When you donate to a project, we share your name and contact information and the amount of your donation with the project leader and organization running that project.
  • When you donate to a fundraiser, we share your name and the date and amount of your donation with the person who created the fundraiser.
  • When you make a donation that is part of a campaign sponsored by your employer, and/or when your employer is being asked to match your donation, we will share your name, email address and the amount of your donation with your employer.
  • Each time you donate, however, we will give you the opportunity to tell us not to share your personal datain the ways described above (except in the case of employer matched donations) by selecting to be “anonymous” during the checkout process.

If HavasuMemorialWalkway merges with, or becomes an affiliate of another organization, we will ensure the confidentiality of any personal data involved in such transactions and provide notice before personal data is transferred and becomes subject to a different privacy policy.

We may also be required to disclose your personal data in the following circumstances: (1) we need to respond to a subpoena, court order or legal process, including to meet national security or law enforcement requirements; (2) an emergency situation requires disclosure before your permission can be obtained (e.g., situations involving potential threats to personal safety), or; (3) we determine that disclosure is needed to protect our rights or property, or the rights or property of another person, in which case we will implement appropriate safeguards to ensure that your personal data continues to be protected.

We may share aggregated demographic and statistical information with our other partners. This is not linked to any personal data that can identify any individual person.


Like most websites, our servers automatically collect certain technical information when you visit our Website, including your IP address, browser type, browser language, the date and time of your visit, the referring URL, and, if you have visited our Website before, one or more cookies that may uniquely identify your browser. We also collect information about your activities on the Website, such as the pages you access.

In order to collect this information, the Website places a cookie on your hard drive. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. We also use web beacons and other technologies to track usage patterns.

We use several tools to collect information about use of this Website. These tools collect information such as how often you visit this Website, what pages you visit when you do so, what elements you interact with, what other sites you used prior to coming to this Website, or 3rd-party audience data (such as age, gender and interests). We use the information we get from these tools to improve our Website, for website analysis and statistics and respond to service requests you make.

Where required by the law, when you first visit the Website, you will be asked to consent to the use of cookies on the Website, and if you accept we will store cookies on your computer.

For more details on our use of cookies and similar technologies, please refer to our Cookie Policy.

Information about Children is a general audience website and does not collect information about a visitor’s age. We do, from time to time, partner with other organizations to educate children about philanthropy in general and our work. In those cases, we do not collect personal data from a visitor on pages specifically designed for children.

We do not knowingly collect or store any personal data about children under the age of 16 and we do not offer any of our products or services directly to children under the age of 13.

Your Rights

Right to access: We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes.

Upon request, we will provide you with a copy of the information that we have.

Right to erasure: If you wish to delete your account or have you information removed from our system, you can do so by sending an email to . For privacy and security, requests must come from the email address tied to your account.

Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data, so you can contact them directly.

Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data, so you can contact them directly.

Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Right to object: You may ask us at any time to stop processing your personal data, and we will do so:

  • If we are relying on a legitimate interest (described in this Privacy Policy) to process your personal data — unless we demonstrate compelling legitimate grounds for the processing; or
  • If we are processing your personal data for direct marketing.

Right to withdraw consent: If we rely on your consent to process your personal data you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.

Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the Information Commissioner’s Office (ICO) (details on how to do so can be found on the ICO’s website) or other data protection authority that is authorized to hear those concerns.


We will retain donor’s information for as long as donor’s account is active or as long as needed to provide our services. We may also retain and use your personal data in order to comply with our contractual or legal obligations, audit requirements, resolve disputes, and prevent abuse.

Links to Other Websites

Other websites, including those of our partners (links to which appear on, have their own privacy policies. When you provide personal data at one of those sites, you are subject to the privacy policy of the operator of that site, not the HavasuMemorialWalkway Privacy Policy. We encourage you to read that policy before submitting any personal data.

You should take additional steps to safeguard your personal data online. To learn more about how to protect yourself, visit the Federal Trade Commission website (US) or the Information Commissioner’s Office (UK).

Safeguarding Your Information

HavasuMemorialWalkway understands the importance of keeping your information secure and confidential. We take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data.

Data Storage

Your data will be stored on servers of our hosting service providers in the United States (GoDaddy Servers). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and US and EEA data protection legislation.

Privacy Shield Framework

HavasuMemorialWalkway complies with both the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland to the United States. HavasuMemorialWalkway has certified that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

In compliance with the Privacy Shield Principles, HavasuMemorialWalkway commits to resolve complaints about our processing of your personal data. Individuals with inquiries or complaints regarding our Privacy Policy should first contact HavasuMemorialWalkway at

HavasuMemorialWalkway has further committed to refer unresolved privacy complaints under the Privacy Shield Principles, to the JAMS PRIVACY SHIELD, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint.

Under certain limited conditions, if your complaint is not resolved through these channels, it may be possible for individuals to invoke binding arbitration before the Privacy Shield Panel. For additional information, please visit: HavasuMemorialWalkway will comply with all investigations and enforcement powers of the Federal Trade Commission (FTC) with respect to personal data received or transferred pursuant to each Privacy Shield Framework.

HavasuMemorialWalkway is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Privacy Policy Updates

Our Privacy Policy is regularly reviewed to make sure we continue to serve the privacy interests of our customers. If our information practices change materially, we will notify you of these policy changes by posting them on the privacy page of this website and we will ensure that these changes are brought to your attention.

Contact Us

You may contact us by using the “Contact Us” links on the footer of our Website or by sending an email to We try to reply promptly to every message we receive. This information is used to respond directly to your questions or comments. We also may file your comments and share them with our customer care team to improve our service in the future.

For individuals in the European Union, HavasuMemorialWalkway Foundation has appointed HavasuMemorialWalkway as HavasuMemorialWalkway Foundation’s representative in the European Union pursuant to Article 27 of the GDPR. You may contact HavasuMemorialWalkway UK at: 314 London Bridge Rd, Lake Havasu City, AZ 86403.