Privacy Policy

Privacy Policy – Swiss American Giving GmbH (SAGG)

Effective Date: July 23, 2025

Introduction

Swiss American Giving GmbH (“SAGG,” “we,” “us,” or “our”) is committed to protecting your privacy. We understand the importance of your personal information and handle it with care and respect. Because SAGG is a Swiss-based organization serving donors internationally through our partner organizations, we comply with Swiss data protection law (including the revised Swiss Federal Act on Data Protection, FADP) and applicable United States privacy laws (such as the California Consumer Privacy Act for California residents). We also align with the principles of the European Union’s General Data Protection Regulation (GDPR) where it may apply (for example, when we interact with individuals in the EU/EEA). By using our services or website, you acknowledge and consent to this Privacy Policy. This Policy applies to all individuals who interact with SAGG both online and offline, including donors, fund advisors, grantees, and newsletter subscribers.

Personal Information We Collect

Our website is primarily informational, and we limit the personal data we collect to what you choose to give us. In fact, the only personal information we collect through our website is what you submit via our Contact Us form. All other personal data is collected through offline means (e.g. in paper forms or direct communications) and is not linked to your online browsing activity. Below are the main situations in which we collect personal information:

Information You Provide via Our Contact Form: If you reach out through the “Contact Us” form on our site, we ask for your name, email address, and your message. We use this information only to respond to your inquiry or request. We will not use it for marketing or any unrelated purposes without your consent. If your inquiry involves international charitable giving or establishing a donor-advised fund, we shall share your basic contact details with our trusted partner, TrustBridge Global Foundation, so that either SAGG or TrustBridge can assist you further in that context.

Information About Related Individuals: In certain cases, you may share personal information about other individuals with us during your interactions. For example, if you are establishing a legacy gift or a joint charitable fund, you might provide the names or details of family members (such as a spouse or children) or other related parties. We treat this information with the same care as your own. We only collect such information if you choose to provide it to us, and we use it solely for the specific purpose for which you provided it (for instance, to include a family member in a fund or grant). In limited cases, to comply with laws and regulations (such as Anti-Money Laundering and counter-terrorism financing rules for international grants), we might need to collect identifying information about key individuals associated with an organization or donation.

How We Use Personal Information

SAGG’s primary purpose in collecting personal information is to serve you better and to carry out our charitable mission. We use the information you provide for purposes including:

Providing and Managing Services: Fulfilling your grant recommendations and donation requests and administering your donor-advised fund through our partner organization.
Communication: Responding to your inquiries and requests, sending confirmations and receipts for your donations, and providing customer support or guidance as needed.
Personalized Experience: Sending you relevant updates such as reports on the impact of your grants, project updates, or tailored educational and marketing materials matching your interests (but only if you have explicitly agreed to receive such communications).
Improving Our Services: Analyzing feedback and engagement with our programs so we can improve user experience and enhance SAGG’s offerings for the charitable community. (For instance, we may review aggregate information or inquiries to refine our website content and services.)
Legal and Compliance: Maintaining accurate records for accounting, auditing, and regulatory purposes, and complying with any legal obligations or reporting requirements (such as tax regulations or charity oversight laws).

We collect only the personal information that is necessary for these purposes, and we do so in a fair and lawful manner. SAGG will not ask for or retain personal data that is irrelevant or excessive in relation to the purposes described above.

Data Sharing and Disclosure

We treat your personal information with confidentiality and care. SAGG does not sell, trade, or rent your personal information to third parties for their own marketing or commercial purposes – we value your trust and will never monetize your data. There are, however, certain circumstances where we may share your information with others, as outlined here:

Service Providers and Trusted Partners: We may share personal information with a limited number of trusted third-party service providers and affiliated organizations, but only for the purposes described in this Policy or otherwise with your consent. For example, we use service providers to help with operational tasks such as data hosting and storage, secure payment processing, email distribution, auditing, or survey collection. These providers are given only the information necessary to perform their specific services, and they are contractually obligated to safeguard your data and not use it for any other purposes. Because SAGG works within a global network of charitable foundations to facilitate cross-border giving, we may also share your information with our network partners (such as TrustBridge Global Foundation) when necessary to process your donation or to provide international giving services (for example, issuing required tax receipts in multiple jurisdictions). In the case of establishing a donor-advised fund, as noted above, your contact details may be forwarded to TrustBridge Global Foundation to initiate the fund setup, and TrustBridge will then collect any additional personal data directly from you for onboarding. In all such cases, any third-party recipients of your data are bound to protect it and to use it only for the intended services or as required by law.
Legal Compliance and Protection: SAGG may disclose personal information if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, regulation, legal process, or enforceable governmental request (including lawful requests by authorities outside your country of residence); (b) enforce or apply our Terms and Conditions or other agreements, or investigate and protect the rights, property, or safety of SAGG, our supporters, or others (for example, to prevent fraud or address security or technical issues); or (c) fulfill mandatory reporting obligations to regulators or government agencies (for instance, reporting charitable donations to tax authorities as required by law). If we are ever required by law to disclose your information to authorities or third parties, we will, if legally permissible and practical, attempt to notify you of the disclosure.
Audits and Organizational Transfers: On occasion, personal information may be shared in the context of audits or organizational changes. For example, an external auditor reviewing our financial records might see donor names or transaction details as part of their verification process – in such cases, auditors and professional advisors are bound by confidentiality obligations. In the unlikely event of a reorganization or structural change involving SAGG (such as a merger, the creation of a successor charitable entity, or a transfer of SAGG’s assets to another charitable organization), personal information may be transferred to the new entity as part of that process, under the same privacy protections described in this Policy.
Identity and Confidentiality: The identity of all individuals who contact SAGG or participate in our programs is kept confidential within our organization and its network. Within SAGG (and our partners and service providers acting on our behalf), access to personal data is restricted to personnel who need to know that information in order to communicate with you, provide SAGG’s services or information you have requested, maintain our records, or fulfill legal, compliance, and reporting obligations. Everyone at SAGG or our partner organizations who handles personal data is trained to treat it with care and confidentiality.
Mailings and Communications: We will not share your personal information with other organizations for their own mailing or marketing purposes without your express permission. SAGG does not send mass communications on behalf of unaffiliated organizations. We may, however, use third-party companies to help distribute our own communications or run surveys – for example, using an email service provider to send out a SAGG newsletter or using a research firm to conduct a donor satisfaction survey on our behalf. In these cases, the third parties act purely under our direction and can use your information only to send the specific SAGG communication or compile anonymous feedback, not for any unrelated purposes.

Data Security and Retention

Protection of Your Information: SAGG takes appropriate technical and organizational security measures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We utilize industry-standard security practices and protocols. For example, if you provide sensitive personal information to us (such as financial information or identification numbers), we ensure that data is encrypted during transmission (using HTTPS/SSL encryption for online submissions) and protected in storage. We also employ firewalls, secure servers and data centers, and access controls to safeguard electronic data. Physical records (if any) are kept in secure facilities with access limited to authorized personnel only. Additionally, we continuously train our staff on privacy best practices and confidentiality obligations to reinforce the importance of protecting your data.

Retention of Data: We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws (for example, tax, accounting, or regulatory requirements). For instance, we may keep donation records for a number of years to comply with Swiss charity regulations and U.S. tax laws. When personal data is no longer needed for our operational needs or legal obligations, we will securely delete it or anonymize it so that it can no longer be associated with you.

No Guarantee of Absolute Security: While we strive to protect your information using robust measures, no method of data transmission or storage can be guaranteed to be 100% secure. Therefore, we cannot warrant absolute security of your information, especially for data transmitted over the internet or via email. You transmit personal information to us at your own risk, and we encourage you to take appropriate precautions as well (for example, using strong passwords, using secure networks, and logging out of any accounts on shared devices). In the event we become aware of a data breach that compromises your personal information and poses a high risk to your rights or safety, we will inform you and the relevant authorities as required by law.

Website Usage and Cookies

Your privacy in using our online services is just as important to us as when you engage with us offline. Here is how we handle data when you visit our website:

Anonymous Browsing: You are welcome to explore the public areas of SAGG’s website without revealing your identity. If you are simply browsing our informational pages, we do not know who you are. We do not use any cookies, tracking scripts, or fingerprinting tools to identify or profile visitors. Our web servers do, however, automatically log certain technical information about your visit in server logs – such as your device’s IP address, the type of web browser and operating system you are using, and the date and time of access. We use this data only in aggregate form to help monitor our site’s performance, ensure IT security, and improve the website’s functionality. We do not use this information to identify individual visitors, except if necessary to investigate security incidents or abuse of the site.

No Cookies or Tracking Technologies: SAGG’s website does not use cookies or any similar tracking technologies. We do not deploy third-party analytics services (such as Google Analytics) on our site, and we do not use advertising trackers or social media pixels. This means that when you visit our site, we are not placing any cookies on your browser for tracking or analytics purposes, and we are not collecting information about your browsing behavior to build marketing profiles. You will not see any cookie consent banner on our site, because we simply don’t set optional cookies that would require consent. (The only cookies you might encounter are basic session cookies that your browser or our hosting platform requires for technical functionality, if any – and those would be transient and not used to track you.) By not using cookies or third-party trackers, we provide you a more privacy-friendly browsing experience. Of course, you have control over cookies through your browser settings in general – but on our site, there is no need to adjust those settings, since we aren’t actively using cookies in the first place.

Your Rights Under GDPR and Swiss Law

As an individual interacting with SAGG, you have certain rights regarding your personal data under applicable data protection laws. In particular, individuals in Switzerland are protected by the Swiss FADP, and if you are in the European Union (or otherwise subject to the GDPR), you have similar rights under the GDPR. SAGG is committed to honoring these rights. In plain language, you have the right to:

Access Your Information: You can request confirmation of whether we are processing any personal data about you, and if so, ask for a copy of the personal information we hold about you. You also have the right to ask for additional details about how we use your data, who we share it with, and how long we plan to keep it, to the extent required by law.
Correct or Rectify Your Information: If any of your personal details we have are inaccurate or incomplete, you have the right to request that we correct or update them. We strive to keep our records up to date and accurate, and we encourage you to notify us if you spot any inaccuracies in the information we hold about you.
Delete Your Information: You can ask us to delete or erase your personal data in certain circumstances. We will honor this “right to be forgotten” when applicable – for example, if the data is no longer needed for the purposes for which it was collected, or if you withdraw consent and we have no other legal basis to continue processing. Please note that there are legal exceptions to this right; for instance, we may need to retain certain donation records or communications to comply with charity laws, tax requirements, or other legal obligations. If such an exception applies, we will inform you about it when responding to your deletion request.
Restrict Processing: You have the right to request that we restrict the processing of your personal information under certain conditions. This means we would mark the stored data to be excluded from further use while your request is being considered. For example, if you contest the accuracy of the data we hold, you can request a restriction on processing until we verify the accuracy. Or if you object to our processing based on our legitimate interests, you can ask us to pause processing (aside from storing the data) while we review your objection. During a period of restriction, we will not use or share the data except for storage, to protect the rights of others, or as otherwise legally permitted, unless you consent.
Data Portability: Where applicable by law, you may request to receive a copy of certain personal data that you have provided to us in a structured, commonly used, and machine-readable format (for example, a CSV or JSON file). You also have the right to request that we transmit that data to another organization, if it’s technically feasible. This right mainly applies when the processing is based on your consent or a contract with you and is carried out by automated means. For instance, if you decided to transfer your donor-advised fund to another provider, and it’s legally permissible, we would provide a portable file of the basic personal information you originally gave us so you can more easily transfer your account.
Object to Processing: You have the right to object to certain types of processing of your personal data. Notably, you can always object to the use of your data for direct marketing purposes – if you opt out or object, we will stop using your data for marketing immediately. You can also object if we are processing your data based on a legitimate interest (either ours or a third party’s); in such cases, if you lodge an objection, we will re-evaluate our reasons for processing and will stop processing your data unless we can demonstrate compelling legitimate grounds to continue (or if we need to continue for legal reasons).
Withdraw Consent: If we are processing any of your personal data based on your consent (for example, you opted in to receive a newsletter or you agreed to a specific use of your information), you have the right to withdraw that consent at any time. You can do so by contacting us using the information below. Once you withdraw consent, we will stop the processing that was based on your consent. Please note that withdrawing consent does not affect the lawfulness of any processing we carried out before your withdrawal. Also, sometimes we might have other legal grounds to process your data aside from consent – withdrawing consent won’t affect processing done on those other grounds. (For example, if you withdraw consent for our newsletter, we will stop sending it, but we might still process certain data to fulfill a donation you made, which doesn’t rely on consent.) If withdrawing your consent means we can no longer provide you with a service (for instance, an email newsletter), we will let you know that consequence at the time of your request.

Exercising Your Rights: You will not have to pay a fee to exercise these rights. We will respond to your requests as soon as possible and in accordance with the timelines required by law (generally within 30 days under the GDPR and Swiss law, with the possibility of a reasonable extension if necessary). To exercise any of your rights, you can contact us using the contact details provided in the “Contacting SAGG” section below. For your security, we may need to verify your identity for certain requests – for example, we might ask you to provide information that matches our records or complete a verification step, to ensure we are honoring the request for the correct person. If your request is unusually complex or if you have made a number of requests, we may need more time to respond, but we will inform you of this. In rare cases, we might be unable to fulfill your request if an exemption applies (for instance, if you request deletion but we are required by law to keep certain records). If we deny your request, we will explain why.

Your Right to Complain: We take your privacy concerns very seriously. If you believe that SAGG has not handled your personal data properly, or if you have any complaints about our privacy practices, you have the right to lodge a complaint with the appropriate supervisory authority. If you are in Switzerland, you can contact the Swiss Federal Data Protection and Information Commissioner (FDPIC). If you are in the European Union, you may reach out to the data protection authority in your country of residence. Of course, we encourage you to contact us first with any concerns – we truly appreciate the opportunity to resolve your issue directly and assure you that we will do our best to address the matter in a satisfactory way.

California Privacy Rights

If you are a resident of California, you are entitled to additional rights and disclosures under California law. SAGG is committed to extending appropriate privacy protections to our U.S. supporters, including compliance with the California Consumer Privacy Act (CCPA) where applicable. Under the CCPA (and related California privacy laws), California residents have the right to:

Right to Know: You can request that we disclose the categories of personal information we have collected about you, the categories of sources from which that information was collected, the business or commercial purposes for collecting (or sharing, if applicable) your information, and the categories of third parties with whom we share your personal information. You may also request a copy of the specific pieces of personal information we maintain about you. (Please note that, in general, we do not collect highly sensitive personal information about California consumers beyond what is described in this Policy, unless you have provided it to us in the course of your interactions.)
Right to Delete: You can request that we delete the personal information we have collected from you. Once we receive and verify your request, we will delete your personal information from our records (and direct our service providers to do the same), unless retaining the information is necessary for us (or our service providers) to complete a transaction or service you requested, to detect or prevent fraud or illegal activity, to exercise our rights or comply with a legal obligation, or if another CCPA-recognized exception applies.
Right to Opt-Out of Sale of Personal Information: The CCPA gives you the right to opt out of the “sale” of your personal information. However, as noted earlier in this Policy, SAGG does not sell personal information to any third parties. We also do not share your data for cross-context behavioral advertising (the kind of tracking across websites that is considered a “sale” under CCPA). Therefore, there is no need for you to take any action to opt out of data sales – we have already effectively opted you out by not engaging in those practices.
Right to Non-Discrimination: SAGG will never discriminate against you for exercising any of your privacy rights. This means we will not deny you services, charge you a different price, or provide a different level or quality of services just because you made a privacy request. (Keep in mind, if you ask us to delete certain essential data, we may not be able to provide a specific service – for example, if you asked us to delete all information about you, we would no longer be able to maintain your donor-advised fund. If such a situation arises, we will inform you of the consequence, but this is not “discrimination” – it is simply a result of your request.)
“Shine the Light” Law: California’s “Shine the Light” law (Civil Code § 1798.83) allows California customers with whom we have an established business relationship to request, once per year, a notice regarding what categories of personal information (if any) we shared with third parties in the prior calendar year for those parties’ direct marketing purposes, and the names and addresses of those third parties. SAGG’s policy is to not disclose your personal information to any third party for their own direct marketing without your explicit consent, so in practice we do not engage in the type of sharing that this law typically covers. If you would like to make a “Shine the Light” request, or otherwise exercise your California privacy rights, you can do so by contacting us as described below. We will respond within the timeframe required by law (generally within 30 days for “Shine the Light” requests).

Submitting Requests (California): If you are a California resident and wish to exercise any of the above rights, you (or an authorized agent acting on your behalf) may contact us using the contact information in the next section. For CCPA requests, we will need to verify your identity (and if you use an authorized agent, we will require proof of the agent’s authority to act on your behalf) before responding, as required by law. We aim to respond to verifiable consumer requests within 45 days as the CCPA mandates (and we will let you know if we need more time). “Shine the Light” requests, which must be submitted to us in writing (by mail or email), will be answered within 30 days as required by that law.

Contacting SAGG and Managing Your Information

We welcome any questions, concerns, or requests you might have regarding your personal data or this Privacy Policy. If you would like to access, update, or correct your information, or exercise any of your rights described above, or if you have a privacy-related inquiry or complaint, please contact us:

Email: admin@trustbridgeglobal.com
Mailing Address: Swiss American Giving GmbH, c/o Invethos AG, Taubenstrasse 8, 3011 Bern, Switzerland

For security and record-keeping purposes, certain requests (for example, a request to delete your data or receive a copy of your data) may need to be made in writing. If you contact us by email with a request related to your personal information, we may take steps to verify your identity or ask for additional information to ensure that we are responding to the correct individual. We will use any information you provide in connection with a privacy request only to fulfill and document that request.

If you receive our newsletter or other promotional emails, you can opt out at any time by clicking the “unsubscribe” link in the email or by contacting us to request removal. Even if you opt out of marketing messages, we may still send you important administrative or transactional communications. For example, we might send a donation receipt, an important notice about your account or fund, or other non-promotional communications as needed to provide our services to you.

Changes to this Privacy Policy

SAGG may update or revise this Privacy Policy from time to time to reflect changes in our practices or to ensure we remain compliant with evolving privacy laws. If we make significant changes, we will post the updated Privacy Policy on our website with a new “Effective Date,” and we will notify you through additional means if required (for example, we might send an email notification or display a prominent notice on our website’s homepage). By continuing to use SAGG’s services or website after a revised Privacy Policy is posted, you acknowledge and agree to the updated terms of the Policy.

We encourage you to review this Privacy Policy periodically so that you stay informed about how we protect your personal information. If you do not agree with any updates or changes to the Policy, please discontinue use of our services and contact us to address your concerns if necessary.

Thank you for trusting Swiss American Giving GmbH with your charitable giving. We are dedicated to safeguarding your personal information and enabling generosity in a secure, transparent manner. If you have any questions or need further clarification about this Policy, please do not hesitate to reach out to us using the contact information provided above. Your privacy is important to us, and we will continue to do our utmost to protect it and to earn your trust.