Terms of Service & Policies
Introduction
These Terms of Service, Donation Policy, Compliance and AML, Privacy Policy (the “Donation Policy”, Compliance and AML Policy”, “Privacy Policy”, “Policy”) are legal agreement between Intersect Entrepreneurship Charitable Society (“Intersect”, “RISE Palestine”, “us”, “we”, “our”) operating RISE Palestine program/initiative and its website (including all its translated versions) risepalestine.intersecthub.org (the “Website”) and you (“website user”, “donor”, “you”).
On 11/03/2024, the Intersect Entrepreneurship Charitable Society (Intersect) launched the RISE Palestine program, which aims mainly to achieve Intersect’s vision of building a modern entrepreneurial ecosystem that possesses all the elements of resilience, development and growth, with its pillars being innovative, entrepreneurial Palestinian youth, capable of creating, proposing and designing technological solutions. Impactful at all local, regional and global levels.
Intersect encourages all interested individuals and institutions to support this program because of its profound and sustainable impact in supporting startups, companies and freelancers in the technology sector. Contributing to the resilience and development of the Palestinian innovation and startup ecosystem, one of the most important pillars of the Palestinian national economy.
In order to enhance the principles of transparency and integrity, and in order to facilitate, accelerate and document the donation process, Intersect invites supporters of the RISE Palestine program to donate through its website, or sub-sites affiliated with its main website in accordance with the policy shown below:
Objective and perspective of donation policy
- This policy explains specific principles and procedures for accepting, receiving, processing and managing donations to the RISE Palestine Program.
- Intersect commits through this policy with the following principles:
- Transparency, integrity, accountability and mutual trust.
- Agreement on principles,interests, and goals between Intersect and the donor.
- Respect the donor’s privacy and commit to preserving their data and its confidentiality.
- Striving to build networks, relationships, and sustainable partnerships with the donor.
- Adherence to local and global compliance laws, instructions and procedures such as AML instructions and KYC
- Inclusiveness and diversity in accepting donations
- This policy applies to all donations made by credit cards, bank transfers, checks and cash.
- Intersect do not accept In-kind donations to this program.
- Donations are accepted from individuals and institutions alike from inside and outside Palestine.
- Donations are used only to support Palestinian tech startups, established tech companies, entrepreneurs, and tech freelancers in the Gaza Strip, the West Bank, and East Jerusalem affected by the current war on Gaza.
- Donations will not be accepted from individuals or organizations that do not share Intersect with its vision, interests and goals.
- The donor does not have the right to impose conditions that differ from or conflict with the objectives of the program and/or are inconsistent with the capabilities, policies and procedures addressed by Intersect.
- Donations from ineligible donors will not be accepted under Intersect Or the Bank of Palestine compliance procedures, and/or any relevant laws or instructions in force.
Forms and methods of donation
- Donations can be made in one of the following ways:
- Via the internet
- Credit cards: Donations are made through the Intersect website risepalestine.intersecthub.org Or payment links provided by the Bank of Palestine Secure payment gateway (Lhaza).
- Bank transfers: The donation process is completed via a bank transfer to the Intersect account at the Bank of Palestine, by completing application form on Intersect website risepalestine.intersecthub.org, and receiving the bank details by email.
- Personal/Bank Cheques Donation to Intersect’s main office in Ramallah or one of its branches in Nablus and Hebron.
- Monetary donation: The donation made through deposit value is cash directly into Intersect account shown below after filling out the online donation form.
- Via the internet
- All donations to RISE Palestine are deposited into a bank account held by Intersect specific to the program at the Bank of Palestine:
0458/3207788/001/3000/003
PS47 PALS 0458 3207 7880 0130 0000 3
Donation management
A. Receiving donations:
Donations are received and the receipt process is documented according to the method of donation, which is as follows:
1. Credit cards
- Every donation is recorded in Intersect accounts before deducting any bank commissions; a separate entry contains the name of the donor, the date of the donation, and the value of the donation.
- Commissions are deducted for banking fees charged by PalPay, which owns and operates the LAHZA secure payment gateway, in an independent accounting record.
- A notification is sent by email to donors confirming the receipt of the full amount of the donation value within minutes to several hours from transfer time.
2. Bank transfers
- Each donation is recorded in full in its original value in Intersect account before deducting any bank commissions, a separate entry contains the name of the donor, the date of the donation, and the value of the donation.
- Commissions are deducted for banking fees charged by Bank of Palestine or other intermediary banks in a separate accounting entry.
- A notification of receipt of the full amount of the donation value will be sent to the donor’s email within five working days from the date/time of the bank’s notification of the transfer entry.
3. Bank Cheque
- Personal cheques are received and a receipt is issued to the donor upon receival.
- Non-personal cheques are not accepted.
- Commissions are deducted for banking fees charged by Bank of Palestine or other intermediary banks in a separate accounting entry.
- A notification of receipt of the full amount of the donation will be sent to the donor’s email within five business days from the date/time of the bank’s notification of the credit cheques to the account.
4. Cash donations
- Cash is deposited directly by the depositor into Intersect account.
- Deposits are being recorded in the Intersect accounts immediately after notifying the bank that the cash deposit has been credited to its account.
- A notification of receipt of the full amount of the donation will be sent to the donor’s email within five business days from the date/time of the bank’s notification of the cash deposit in the Intersect account.
B. No donation will be accepted unless it is confirmed that the policy conditions are met and procedures and compliance of the Bank of Palestine applies to the concerned donor.
C. Banking settlements:
- Intersect is enabled with online banking services to its account to manage the program’s donations account.
- In case donation occurs via credit cards or online bank transfers. The value of the donation is confirmed and inserted by the donor before making the transfer.
- Coordination takes place between Intersect, the Bank of Palestine, and the management of the LAHZA secure payment gateway to verify donor data and details of their donations.
- Periodic bank reconciliations are prepared monthly or when necessary to ensure that all donations and their owners’ information are recorded and any errors are settled and processed, whenever it may appear, it is immediately resolved in an appropriate manner.
D. Receipt notices
- A notification is sent by an automatic email to thank everyone who donated online via credit cards and/or bank transfers.
- An immediate response is followed if a notification/complaint is received from the donor regarding their donations, and dealing with what was stated there.
- The donor will be notified via Email with the result of the investigation/examination and treatment of what was stated in his notice/complaint.
E. Modify/Return Donations
- The donor via online credit cards has the right to: Modifying the value/canceling his donation within a period not exceeding three(3) days from the date of confirmation of the donation via the website. Donor must submit their desire to modify/return donation to the program within three (3) days.
- The donation is returned fully or partially within sixty (60) days from the date of receipt of the concerned donor’s notification to modify/return, after reviewing the original transfer/recording of the donation process.
- Following the previous item, any donations will not be returned after three(3) days from the date it is received and recorded in Intersect’s accounts.
- Any problem regarding modifying/returning a donation will be resolved through a committee consisting of at least two members of the Finance Committee, once it issues its decision within thirty (30) days from the date of receipt of the donor’s notice/complaint, and its decision must be final.
- Any donations that may not be spent for the purposes of the program as a result of force majeure circumstances that prevented the implementation or completion of the program will not be returned.
- Later to the previous items, Intersect adhere With:
- Disbursing the remaining donations for the purposes of the same program immediately after the disappearance of the reasons and force majeure that prevented its implementation/completion.
- Exchange of remaining donations to similar programs implemented by Intersect whenever possible.
- Allocate and disburse the remaining donations to other programs conceived and implemented by Intersect.
- Can not donate the remaining donations to a third party or authorize it to implement the program in whole or in part.
- To retain the remaining donations, with having the right to use them in the future according to what Intersect management deems appropriate.
- Intersect is committed to announcing, through appropriate means determined, to notifying donors whenever possible about:
- Force majeure reasons that prevent the implementation/completion of the program.
- Completion date of the program immediately after the disappearance of force majeure reasons/circumstances.
- Alternative Program/s that Intersect will implement and the expected date(s) for that.
Reports and communication with donors
Commitment to the principle of transparency
Intersect is committed to implementing the program with the highest levels of transparency and providing periodic monthly summaries about the program related to the value of the amounts collected, the aspects of their disbursement, the successes it achieved, and the challenges it faces in implementing the program.
Periodic reports
- Intersect is committed to preparing quarterly reports for all donors detailing the expenditure of donations and the program outcomes achieved. The reports also present the stages of program implementation, the extent to which it achieves its goals, success stories of beneficiaries, and general financial data and statistics related to the program.
- These reports are formulated in Arabic and English, in simple, understandable language, supported by graphs and pictures that illustrate the impact of the program.
- These reports are uploaded to the program’s website, and all donors and interested parties can download, access and browse these reports and use it in their promotional activities, provided that they comply with applicable copyright laws.
Financial transparency
- Intersect is committed to periodic auditing by an independent external auditor in the annual financial report for Intersect and all its programs. All donations collected and their disbursements are subjected to the periodic audit, knowing that these reports will not be published on Intersect website Or the program website.
- Intersect may use whatever data it deems appropriate from the audited financial reports and include it in its own promotional reports or bulletins and publish it in any form and through means that suit the nature of its work and achieve its interests and goals.
- These reports and promotional material might be uploaded to the Intersect/Program website and all donors and interested parties can access, browse, download and use these reports. They can use it in their promotional activities, provided that they adhere to applicable copyright laws.
Reports and special bulletins
- Donors whose donations exceed Fifty Thousand USD Or its equivalent in other currencies can request unaudited reports and special bulletins related to the program (the value of donations, their disbursements, program outcomes, …) with the aim of using them in advertising or media bulletins.
- Intersect determines the form and content of the reports/bulletins mentioned in the previous clause in consultation with the donors concerned.
- These reports/bulletins are drafted in Arabic and/or English.
- Special reports/bulletins are the sole property of Intersect and Intersect has the right to use them for its own purposes as it deems appropriate without prior permission from the donors concerned.
- Taking into account the principles of privacy of relevant parties, specifically donors and beneficiaries, Intersect has the right, without prior permission from any of the relevant parties, to hold conferences or publish press releases related to the program as it deems appropriate.
Ethics principles and conflict of interest
- Intersect is committed to adopting the highest standards of integrity and transparency in planning, managing and implementing its donation campaign for the program through the use of materials, bulletins and reports, regardless of their format and means of publication, that contain correct, accurate data and information and content that respects donors and beneficiaries alike.
- Intersect is committed to respecting the independence and dignity of donors by providing them with information statements in a correct and accurate insights on the progress of the program and its goals, procedures for collecting donations, aspects of their disbursement, and the size and shape of the expected impact, which enables the donor to make correct decisions without being misled.
- Intersect is committed to do everything in its power to ensure that there are no conflicts of interest, both at the personal level and at the institutional level, when making any decisions related to the implementation of the program, especially those related to identifying the beneficiaries of the program and the form and value of the support provided to them through it, as:
- Intersect is committed to obligate the members of its Board of Directors and employees who manage the program to immediately and clearly disclose in writing, in a complete and clear manner, any potential conflict of interest that may affect the objectivity or impartiality of their decisions, including, but not limited to, kinship and/or personal and/or professional connections.
- Anyone who has a conflict of interest (board member, employee) will be excluded immediately.
- Intersect is committed to embodiment of its principles and values, by developing and implementing procedures and setting clear, fair and impartial standards and applying them objectively and impartially in evaluating and selecting beneficiaries in a manner consistent with the program’s objectives and enhancing its impact.
Compliance and AML Policy
When recruiting and receiving donations, Intersect is committed to fully complying with all applicable laws and instructions related to money laundering (AML) applied by the Bank of Palestine, in line with the principles of transparency and accounting it adopts.
Therefore, Intersect adopts and applies strict professional procedures to prevent, identify and notify the relevant authorities about any illegal/illicit financial activities related to money laundering.
The role and responsibilities of the Bank of Palestine - KYC policy and procedures
In order to implement its legal compliance obligations and ensure the integrity of its financial activities, Intersect cooperates closely with the Compliance Department at the Bank of Palestine, which applies KYC inspection and audit procedures on a regular, professional, and accurate basis to all donation transactions that meet the conditions (bank transfers, cheques, and cash donations), thus integrating these checks and audits are consistent with Intersect’s policy and procedures in recruiting, accepting and receiving donations.
The Bank of Palestine is responsible for examining and verifying the identity of individuals and institutions that donate to Intersect. The examination and audit process may include collecting and analyzing data in identification documents (identities, passports/ID – Date of birth, registration certificates – date of registration …) and assessing the level and degree of risk for each donor and beneficiary of the program.
Audit and examination procedures
- Compliance department defines the basic data required from individuals and organizations that wish to donate to the program.
- Intersect do the collecting of the necessary data required from donors by filling out the donation form on its website risepalestine.intersecthub.org.
- Intersect grants Bank of Palestine Compliance Department employees authorized access to the necessary data required only, in order to conduct the examination and audit process.
- The Compliance Department is committed to using data for KYC purposes only.
- The Compliance Department handles:
- Examining and auditing the data of donors, individuals and institutions, including: names, addresses, date of birth/registration date, and work on comparing it with their own databases.
- Evaluate the level and degree of risk for each donor according to specific criteria that it adopts.
- The Compliance Department is committed to examine and verify the data of a specific donor at every donation they make.
- The Compliance Department shall inform Intersect of the results of the examination and audit and notify any third party in accordance with the relevant laws in force and/or in compliance with its policies and procedures in this regard.
- The Compliance Department bears all legal and financial responsibilities resulting from any error it makes in assessing the level and degree of risk for a specific donor.
- The Compliance Department is committed to informing Intersect of any updates on the necessary data required.
- Intersect is committed to updating the donation form immediately to ensure obtaining the necessary updated data required by the compliance department.
- The Compliance Department is committed not to share any donor data with any third party other than what is legally required of it.
- The Compliance Department is committed to maintaining the privacy and confidentiality of donor data in accordance with the privacy and confidentiality principles adopted by Intersect and the relevant laws in force.
- It is the responsibility of the Compliance Department to update its databases.
- Intersect informs the donor that he is not eligible to donate to the program and does not bear any responsibility in this regard.
- Intersect is committed to notifying the competent official authorities about the result of examining and auditing donor data or any illegal/suspicious activities in accordance with what is approved by the relevant laws in force.
- Intersect maintains the data of all donors, both eligible and ineligible, in its database and the results of each of them that it received from the Compliance Department for the purposes of financial auditing or auditing for special purposes by official bodies authorized under the relevant laws.
Privacy Policy
Data types
Only donor data necessary for the objectives of the RISE Palestine program/initiative is requested and collected and is divided into:
- Mandatory data: This is basic data necessary in compliance with the relevant laws in force as well as in compliance with the compliance policies of the Bank of Palestine and includes (first name, last name, E-mail,contact number, address, donation value, and Credit card data) and marked with (*) in the donation form on the website.
- Optional additional data: This is data necessary for the purposes of managing the program, measuring its effectiveness and impact, through statistics and issuing reports, to build relationships with those who contribute to the success of the program, including (job title, name of the employing institution) and marked with (optional) in the donation form on the website.
Areas of data use
Intersect is committed to using donor data only for the following purposes:
- To treat the financial transactions related to the donation process, such as: Issuing receipts.
- Preparing financial reports and submitting them to the competent authorities as required by the relevant laws in force.
- Communicate with donors in an appropriate manner with the aim of:
- Thanks and appreciation direct messages for their contribution through donation.
- Inform them of how their donations will be used.
- Informing them of the program’s developments, results and impacts.
- Inform them about new programs, initiatives or related donation campaigns.
- Obtaining feedback regarding the donation process
- Preparing reports to show how donations are used, the level of progress in program implementation, and the tangible effects on program beneficiaries.
- Preparing and implementing surveys and opinion polls aimed at developing the organization’s strategies for networking, managing and strengthening its relationships with the current and potential donor audience.
- Analyze and study donors’ interests better to be able to plan and implement new donation campaigns in an effective manner.
- Analyzing the organization’s internal performance and the effectiveness of its related systems, such as analyzing and following up on donation patterns, predicting the size of donations from future campaigns, and managing relationships with donors.
Saving and protecting your data
- Intersect is committed by collecting, processing, storing and preserving donor data according to the highest standards, protecting it and providing an appropriate technological infrastructure for this purpose (Devices, Advanced computers, modern protection programs, Cloud servers, …) in strict administrative systems and procedures (encryption, specific permissions and roles at different levels, auditing and updating data security policies and procedures, storage in trusted locations, …) are applied in this field. And to ensure that information is not accessed and/or used/exploited legally by any third party without permission from Intersect And/or use/exploit it in a manner that’s not legal from a third party and/or altering and/or disseminating or destroying it.
- Intersect is committed by maintaining the privacy of the data provided by donors. Where Intersect adopts strict policies and procedures that are applied within related privacy and to access donor data to a specific number of qualified, trusted, specialized employees.
- Intersect is committed to not share any donor data with any third party unless necessary in the cases mentioned below, after ensuring the reliability and eligibility of the concerned party and ensuring that it is legally committed not to disclose or exploit any of the data given to it for illegal purposes. Intersect data sharing should be as minimal as possible:
- A competent official body authorized under the relevant laws in force to conduct a legal investigation and/or conduct an examination of the extent of compliance. Intersect Compliance principles, compliance policies and procedures approved by the competent official authorities.
- Submitting reports to the relevant official departments regarding the revenues and grants Intersect has received.
- Issuance of a binding judicial order relating to Intersect Or the donor.
- Accounting and administrative audits for Intersect Or those carried out by competent official bodies under relevant laws.
- An audit and examination related to preventing money laundering is conducted by competent authorities, whether official, governmental, or unofficial, such as the Bank of Palestine, before and after receiving donations.
- The donor has the right to access their main private data via the internet to update or correct it, including: By communicating via email to risepalestine@intersecthub.org with “donor information” in the subject of the email.
Data retention
- Donor data is retained according to data principles And the following requirements:
- Adherence to official and informal laws and instructions related to maintaining financial data related to donations, such as instructions from tax departments.
- There is a financial, administrative, and/or operational necessity that requires this, such as addressing financial restrictions related to donations, communicating with donors, analyzing data, and preparing financial, promotional, and media reports.
- Ensure that donor data is stored and managed securely by specific employees with specific authorized access.
- Donor data is kept for a period of five years subject to modification as required by relevant laws and official instructionsIn particular, Intersect has the right to retain data Or destroy it.
- Taking into account what is stated in the previous clause 4.2, Intersect conducts a periodic audit and review of the data available to it and ensures retention Only the data required, and destroys any data not needed in accordance with what is stated in the clause 4.4.
- Intersect is committed to destroying donor data, regardless of the method and form of its storage (electronic, written/written), in a secure and appropriate technical manner that ensures that it cannot be retrieved immediately after the end and/or no longer need for it, in a way that takes into account and preserves the privacy of donors.
- Intersect is committed to informing and training its relevant employees on what is stated in this policy and ensuring that they understand, implement and adhere to it, especially with regard to principles of maintaining the privacy of donors and using and managing their data in a secure and appropriate manner.
Modifications and policy/ies Updates
- The above policy is reviewed periodically, every six months, or when necessary as a result of amendments to laws and instructions from official bodies or administrative amendments; Or changes on operational Or technological developments that fundamentally affect the content of the policy, the extent of its application, and how it is applied.
- The above policy is reviewed periodically by the Operations Manager and Communications and Outreach Officer at Intersect.
- Intersect board members and employees can suggest amendments to the above policy that they deem necessary.
- The proposed amendments are analyzed and evaluated by the Operations Manager and Communications and Outreach Officer at Intersect according to the following criteria:
- The amendments are consistent with the vision and mission of Intersect and support the beneficiaries of the program.
- Achieve the goals of Intersect represented an increase in recruiting financial support, an increase in the number of donors, enhanced transparency, and increased effectiveness in program management.
- Compliance with local or international laws related to program management (donation laws for associations, compliance principles, money laundering, privacy protection, donor data management and protection, …)
- Maintaining and enhancing the principles that govern the program such as integrity, fairness, transparency and accountability.
- Enhancing donors’ confidence in Intersect and enhancing its reliability in their eyes, such as enhancing and developing communication and communication processes with donors.
- Developing and enhancing Intersect’s capabilities in managing its relationships with donors, such as facilitating and accelerating donation processes, recording donations, informing and thanking donors, and preparing and developing appropriate reports for them.
- Enhancing Intersect’s administrative effectiveness by facilitating and accelerating the processes of receiving and processing donations with greater accuracy and preparing appropriate reports related to them.
- Developing and strengthening Intersect’s capabilities in measuring the impact of the program and preparing reports regarding it.
- The impact of the amendments, positively or negatively, on the program’s beneficiaries and Intersect’s ability to identify and meet their needs and requirements.
- The impact of the amendments has been to increase Intersect’s flexibility and dynamism in responding to and adapting to the changing circumstances surrounding Intersect and its program beneficiaries.
- The extent to which the amendments are able to fundamentally reflect the trends of donors, beneficiaries and partners and respond to their comments, suggestions and criticisms.
- Identify potential risks (administrative, financial, relations/reputation of the institution, …) that may arise as a result of the proposed amendments and evaluate the risks and agility of Intersect in response to it.
- Any amendments proposed by relevant parties (Board of Directors, employees, donors, beneficiaries, partners, …) will be received via email. risepalestine@intersecthub.org with “suggested amendments” in the subject of the email; Or communicate with a member of the organization directly and document the process.
- Proposed modifications are reviewed and evaluated by the Operations Manager and Communications and Outreach Officer.
- Any amendments shall be approved with the approval of the Executive Director of Intersect.
- The policy will be amended in accordance with the approved amendments and republished by the means and through the sites specified for it.
- Relevant employees are trained on the new policy to ensure its proper implementation.
Acknowledgment and approval of donors
The donor acknowledges the following:
- The donor confirms that they have read the above Intersect Donation Policy, understands it, agrees to everything stated therein, and undertakes to abide by all its terms and conditions. The donor understands and acknowledges that his donation to Intersect respects, observes and is fully consistent with the principles, objectives and procedures contained therein.
- The donor acknowledges that all or part of his data will be used, as, when, and as necessary in order to implement the Intersect and Bank of Palestine’s policy and procedures related to Anti-Money Laundering (AML) and the Bank of Palestine’s Know Your Customer (KYC) policy and procedures. The donor also acknowledges and understands the importance of using And implementing the policies and procedures mentioned by Intersect and the Bank of Palestine in preventing and combating fraud, deception, financial corruption and any other illegal activities.
- The donor acknowledges that he has donated to Intersect voluntarily, without pressure or coercion, or without any compensation and/or the promise of any compensation, regardless of its form, and that he has made the donation out of belief in Intersect’s stated mission, principles, goals, and the objectives of the program(s) that they will implement with the donations collected.
- The donor understands and acknowledges that Intersect reserves the right to use his donation in accordance with its discretion, consistent with the objectives of the program(s) it is implementing and within the controls and limits set forth in the above policy.
- The donor acknowledges that their donation to Intersect is final and irrevocable and agrees to the donation return policy set forth in this policy.
- The donor acknowledges that all the data he provided is true, correct and complete and that he bears any legal responsibilities regarding the truthfulness and completeness of the information he provided.
- The donor undertakes and undertakes to notify Intersect immediately of any change in the information he has provided.