Privacy Policy Amendment and Build Brief
Decision
The standalone IsMyNonprofitCompliant Privacy Policy (DRAFT v3) is retired and will not be published. The site is a marketing landing page for lead capture with a free IRS lookup and editorial content. It has no accounts, no payments, and no Crowded platform components. A second full privacy policy creates version drift against the parent policy, which is already at V4.7 and was revised on 29 July 2026.
Instead:
- The parent Crowded Privacy Policy is extended to cover this domain. One policy, one privacy champion, one CCPA intake process.
- A short site-specific Terms of Use is published on this domain, covering only what the parent does not.
Part A. Parent Privacy Policy amendment (V4.7 to V4.8)
A.1 Section A(1), replace in full
Defining both domains into the existing term “Website” avoids a global find and replace through the rest of the document. No other definitional change is required.
A.2 Section B.1, add a new subsection
A.3 Section F, add to the list of third-party recipients
A.4 Section N, correct the address
This is a pre-existing typographical error in the live parent policy. The corrected address matches the site footer and should be used across all Crowded legal documents.
A.5 Version control
Increment to V4.8 and set Last Update to the publication date. Publish the amended parent policy before the landing page goes live.
Part B. Build requirements
B.1 Footer
Link the site-specific Terms of Use and the parent Privacy Policy at bankingcrowded.com/legal/privacy-policy.
Suppress the standard Crowded footer disclosure block on this domain (financial technology company, i3 Bank, Member FDIC, Visa debit card, FDIC sweep, transaction fees). No banking service is offered on this site and including the disclosure implies otherwise.
B.2 Cookie consent
Deploy the same consent management platform used on bankingcrowded.com, with the same categories (Functional, Preferences, Statistics, Marketing). Do not build a bespoke accept-or-decline bar.
B.3 Tag stack, confirm before launch
Shay and Rodi to confirm in writing what actually loads on the page. Expect Google Analytics, the HubSpot tracking script, and potentially LinkedIn, Meta, and retention.com. Every tag that runs must be within the scope of the parent policy and gated behind the consent manager. Nothing non-essential fires before consent.
B.4 Results-page disclaimer, publish verbatim
Display beneath every search result, in legible type:
This is the disclaimer that does the work. Terms of Use text alone is not sufficient protection where a user relies on a displayed result.
B.5 Telephone consent at the form (TCPA)
The form collects a telephone number. Any call or text to that number requires prior express written consent captured at the point of collection. Statutory exposure is USD 500 to 1,500 per call or text and this is heavily litigated. Place the following immediately adjacent to the submit button. If implemented as a checkbox, it must be unchecked by default.
Retain a timestamped record of consent for each submission.
B.6 Editorial content
Blog and article comments are disabled at launch. If comments are enabled later, a user content licence, a takedown process, and a designated DMCA agent are required beforehand.
B.7 No click-through gate
Do not implement an “I Agree” interstitial. It suppresses conversion on a lead page and is unnecessary where there is no account and no transaction. Footer link plus the results-page disclaimer is the model.
B.8 Accessibility
Target WCAG 2.1 Level AA. Public nonprofit-facing sites attract accessibility demand letters.
Part C. Pre-publication checklist
- Effective Date and Last Updated set on the Terms of Use.
- USPTO knockout search completed on “IsMyNonprofitCompliant”. If unregistered, the common law claim in Section 7 stands as drafted.
- Parent Privacy Policy amended to V4.8 and published.
- Parent Terms of Service Section 12 confirmed as Delaware governing law. If it is not Delaware, conform Terms of Use Section 10.
- Address rendered as 501 East Las Olas Boulevard, Suite 200, Fort Lauderdale, FL 33301 everywhere.
- Internal status banners removed from all published text.
- Footer banking disclosure suppressed and verified on staging.
- Consent manager live and tags gated, verified on staging.
Part D. Decisions closed
- Standalone site Privacy Policy: retired.
- Contact inbox: info@bankingcrowded.com, consistent with the parent policy. No dedicated inbox.
- Minors threshold: 18, consistent with the parent policy. The earlier draft used 13.
- Binding arbitration and class action waiver: removed. Under AAA Consumer Rules Crowded bears substantially all arbitration cost, which exceeds the entire liability cap on a free tool.
- API section: removed. No API exists and automated extraction is already prohibited under Acceptable Use.
- Compliance services wording: replaced throughout with compliance software and administrative support services, to avoid tension with the no-professional-advice disclaimer.
- External counsel: not required. All items are internal.