Terms of Use

Welcome to Bridgely!

These Terms of Use (or “Terms”) govern your use of the Bridgely platform (“Bridgely”), which is owned and operated by OneChild Global, a Colorado nonprofit corporation, and provide information about the Bridgely Service (the “Service”), outlined below. When you create a Bridgely account or use Bridgely, you agree to these terms.

The Bridgely Service is provided to you by OneChild Global. These Terms of Use therefore constitute an agreement between you and OneChild Global.

ARBITRATION NOTICE: YOU AGREE THAT DISPUTES BETWEEN YOU AND US WILL BE RESOLVED BY BINDING, INDIVIDUAL ARBITRATION. BY USING THE SERVICE, YOU WAIVE YOUR RIGHT TO PARTICIPATE IN LITIGATION IN STATE OR FEDERAL COURT, OR IN A CLASS ACTION LAWSUIT OR CLASS-WIDE ARBITRATION. WE EXPLAIN SOME EXCEPTIONS AND HOW YOU CAN OPT OUT OF ARBITRATION BELOW.

The Bridgely Service

We agree to provide you with the Bridgely Service. The Bridgely Service includes the Bridgely application, features, services, technologies, and software that we provide to advance Bridgely’s mission: to unleash the power of healthy intercultural relationships and effective generosity to break the grip of poverty on a global scale — the poverty in all of us. The Bridgely Service includes the following:

Offering opportunities to connect, communicate, learn, discover, and share.
We want you to build healthy intercultural relationships by giving you opportunities to connect with communities and people around the world that care about similar things as you do – battling poverty and building the body of Christ. That means we provide opportunities for you to share photos, videos, and post content for the purpose of connecting with those who share the same passion to end extreme poverty.
Fostering an encouraging and safe environment.
We develop and use tools and offer resources to our community members that help make their experiences positive and keep them safe. Our partners also have teams that work to combat abuse and violations of our child protection, safeguarding vulnerable people, and community communication policies, as well as harmful and deceptive behavior. We use all the information we have, including your information, to try to keep our platform secure. If we detect a violation of our policies, we also may share information about misuse or harmful content with law enforcement.
Providing opportunities to you to support the causes you care about.
Bridgely partners will provide opportunities for you to support their missions and causes within their hosted communities. When you donate through the Bridgely Service, your payment information is stored within a third-party payment processor. Therefore, Bridgely does not have access to your payment methods, or your payment information.
Ensuring access to our Service.
To operate our global Bridgely Service, we must store and transfer data across our systems and Bridgely partner systems around the world, including outside of your country of residence. The use of this global infrastructure is necessary and essential to provide our Service. This infrastructure may be owned or operated by OneChild Global or Bridgely’s partners.

How Our Service Is Funded

By using the Bridgely Service covered by these Terms, you acknowledge that we charge a processing fee on all donations to cover the cost of the Bridgely Service. Bridgely’s processing fee is withdrawn from your donation prior to granting funds to Bridgely’s partners. You can cover the cost of fees during the payment process if you would like.

Your Commitments

As a Bridgely Service customer, you make representations as to who you are, how you will use the Bridgely Services and the process you agree to follow in the event of a dispute. Please read the following representations carefully, as they are your commitments to Bridgely.

Who Can Use Bridgely. We want our Service to serve those wanting to connect for the purpose of growing healthy intercultural relationships, poverty alleviation and furthering the mission of Christ, AND we also want it to be safe, secure, and in accordance with the law. Therefore,

You must be at least 13 years old.
You must not have had your account previously disabled for violation of law or any of our policies.
You must not be a convicted sex offender in any state or country.

How You Commit to Use Bridgely. Providing the Bridgely Service for a broad range of people necessitates that you:

Be yourself and tell the truth
You agree to not impersonate anyone or create user accounts without an individual’s permission.
Don’t use Bridgely for personal gain.
You agree not to promote your own business or causes. Bridgely connects cause communities on behalf of its partners. The purpose of a community is to engage with the partner’s shared vision.
Don’t do anything unlawful, fraudulent or for an illegal purpose.
Only post content that upholds the dignity of others.
Follow the community rules.
Bridgely’s partners will post clear community rules. If you do not follow the community rules, a community moderator will remove your access for a limited or indefinite amount of time, as the community moderator and/or Bridgely determine in their sole and exclusive discretion. Bridgely administrators and community ambassadors will remove content that infringes on the community rules or Bridgely guidelines stated in this document. Removal of access to the community will not result in a return of any processing fees for any reason.

Consent from you to us. As part of our agreement, you also consent to:

Granting us a license to use the content you post.
You own your content. However, we need legal permissions from you to provide the Service. When you share, post, or upload content (like photos or videos), you are making a representation that you own the content and that you are granting to us a non-exclusive, royalty-free, transferable, worldwide license to host, use, distribute, modify, run, copy, publicly perform or display, translate, and create derivative works of your content.
Permission to share your username, profile picture, and account information with the Bridgely partner who hosts the community(ies) you elect to join.
You agree that we can download and install updates to the Bridgely Service on your registered device.
Bridgely Commitments and Limitations Our Service is provided “as is,” and we can’t guarantee it will be safe and secure or will work perfectly all the time. BRIDGELY AND ITS PARTNERS DO NOT MAKE, AND HEREBY DISCLAIM, ALL OTHER REPRESENTATIONS OR WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, ACCURACY, COMPLETENESS AND NONINFRINGEMENT OF THIRD PARTIES’ RIGHTS. Neither Bridgely or its partners shall be liable for special, consequential, or incidental damages attributed to use of the Bridgely Service provided under this Agreement.
We also don’t control what people and others do or say. We aren’t responsible for the timing of when objectionable content is removed, and we aren’t responsible for any user’s actions or conduct (whether online or offline) or content (including unlawful, offensive, and erroneous content). We also aren’t responsible for services offered by our Bridgely partners or local field partners, even if you access them through the Bridgely Service.
Our responsibility for anything that happens while using the Bridgely Service (also called “liability”) is limited as much as the law will allow. If there is an issue with our Service, we can’t know what all the possible impacts might be. You agree that we won’t be responsible (“liable”) for any lost profits, revenues, information, or data, or consequential, special, indirect, exemplary, punitive, or incidental damages arising out of or related to these Terms, even if we know they are possible. This includes when we delete your content, information, or account. You further agree that our maximum liability arising out of or relating to these Terms will not exceed the greater of $100 or the amount you have paid us in the past twelve months.
You agree to defend (at our election), indemnify, and hold us harmless from and against any claims, liabilities, damages, losses, and expenses, including without limitation, reasonable attorney’s fees and costs, arising out of or in any way connected with these Terms or your use of the Service. You will cooperate as required by us in the defense of any claim. We reserve the right to assume the exclusive defense and control of any matter subject to indemnification by you, and you will not in any event settle any claim without our prior written consent.

How We Handle Disputes.

Except as provided below, you agree that any cause of action, legal claim, or dispute between you and us arising out of, or related to, these Terms or your use of the Bridgely Services (collectively “claims”) must be resolved by arbitration on an individual basis. Class actions and class arbitrations are not permitted. You may bring a claim only on your own behalf and cannot seek relief that would affect other Bridgely users. If there is a final judicial determination that any claim (or a request for particular relief) cannot be arbitrated in accordance with this provision’s limitations, then only that claim (or only that request for relief) may be brought in court. All other claims (or requests for relief) remain subject to this provision.
Instead of using arbitration, you or we can bring claims in your local “small claims” court, if the rules of that court will allow it. If you don’t bring your claims in small claims court (or if you or we appeal a small claims court judgment to a court of general jurisdiction), then the claims must be resolved by binding, individual arbitration. The American Arbitration Association will administer all arbitrations under its Consumer Arbitration Rules. You and we expressly waive a trial by jury.The following claims don’t have to be arbitrated and may be brought in court: disputes related to intellectual property (like copyrights and trademarks), or efforts to interfere with the Bridgely Service or engage with the Bridgely Service in unauthorized ways (for example, automated ways). In addition, issues relating to the scope and enforceability of the arbitration provision are for a court to decide.This arbitration provision is governed by the Federal Arbitration Act.You can opt out of this provision within 30 days of the date that you agreed to these Terms. To opt out, you must send your name, residence address, username, email address, and phone number you use for your Bridgely profile account, and a clear statement that you want to opt out of this arbitration agreement, and you must send them here: OneChild Global. ATTN: Bridgely. 14575 Gleneagle Rd., Colorado Springs, CO 80921.
Before you commence arbitration of a claim, you must provide us with a written Notice of Dispute that includes your name, residence address, username, email address or phone number you use for your Instagram account, a detailed description of the dispute, and the relief you seek. Any Notice of Dispute you send to us should be mailed to OneChild Global. Before we commence arbitration, we will send you a Notice of Dispute to the email address you use with your Bridgely profile account, or other appropriate means. If we are unable to resolve a dispute within thirty (30) days after the Notice of Dispute is received, you or we may commence arbitration.
For any claim that is not arbitrated or resolved in small claims court, you agree that it will be resolved exclusively in the U.S. District Court for the District of Colorado or a state court located in Denver County. You also agree to submit to the personal jurisdiction of either of these courts for the purpose of litigating any such claim.
The laws of the State of Colorado, to the extent not preempted by or inconsistent with federal law, will govern these Terms and any claim, without regard to conflict of law provisions.

Revising These Terms

Our Service and policies may change, and we may need to make modifications to these Terms so that they truthfully reflect our Service and policies. We will notify you through our Service before we make changes to these Terms and give you a chance to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Terms. If you do not agree to these or any updated Terms, you can delete your account.

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FINANCIAL CONNECTIONS TERMS OF USE

Effective Date: January 1, 2025

Welcome to Bridgely (“Company,” “we,” “our,” or “us”). These Financial Connections Terms of Use (“Terms”) govern your use of financial services and payment processing features provided by Nuvei, Inc. (“Nuvei”) through our website www.bridgely.org (“Website”). By linking your financial account to our services, you agree to these Terms.

Financial Data Access & Use

Bridgely uses application program interfaces (“APIs”) to gather donation information from any third-party payor or payment platform that interacts with Nuvei. By connecting your bank account or financial institution through Nuvei Financial Connections, you grant Nuvei and Bridgely permission to:

Account owner information, including your contact information, such as name, physical address and email address.
Retrieve account details, balances, and transaction history to verify financial data.
Facilitate payments, including deposits, withdrawals, and recurring transactions.
Improve fraud detection, risk management, and payment security.
We do not store or access your financial login credentials. All financial data access is managed securely by Nuvei in accordance with their Privacy Policy.

Refund & Return Policy for Digital Donation Services

Due to the nature of digital donation services, all donations are final. However, we understand issues may arise. Refunds will for accidental, duplicate or unintended donations will be made within twenty-four (24) hours. Refunds are not permitted thereafter. Refunds within twenty-four (24) hours will be initiated to you by the third-party payor or payment platform that interacts with Nuvei.

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PRIVACY TERMS OF USE

Bridgely endeavors to provide its services using as little personal information as possible.

WHAT INFORMATION DO WE COLLECT?

In Short: Personal information you disclose to us.

We collect personal information that you voluntarily provide to us when you register for our Services, express an interest in obtaining information about our Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names

phone numbers

email addresses

mailing addresses

usernames

passwords

contact preferences

location data

ip addresses

HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation of the European Union (GDPR) and the Data Protection Act 2018 (UK GDPR) require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Legitimate Interests. We may process personal data on the basis of Legitimate Interest. Legitimate Interest means the interest of our organization in conducting and managing our operations to enable us to provide the best service and the most safe and secure experience. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

For investigations and fraud detection and prevention
For charity/ministry transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, charity/ministry, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations to provide Bridgely’s Services at your request to a third-party.

Charity/ministry Transfers. We may share or transfer your information in connection with providing Bridgely’s Services to our partners globally, but only at your specific request and direction.

Third parties: (i) in the case of an emergency; (ii) to protect or enforce Bridgely’s rights; (iii) to protect or enforce the rights of a third party; (iv) as required or permitted by law (including, without limitation, to comply with a subpoena or court order); (v) to any actual successor-in-interest of Bridgely, in connection with the Services provided.

Bridgely does not sell, rent, loan, trade or lease your information collected on our website.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill our Services to you outlined in this privacy notice, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). We will not keep your personal information for longer than the period of time in which you have an account with us.

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market our Services to children under 18 years of age, without the prior written consent of the parent or guardian.

We do not knowingly solicit data from or market our Services to children under 18 years of age, without the parent or guardian. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us.

DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Under the Virginia Consumer Data Protection Act (CDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data” means the exchange of personal data for monetary consideration.

If this definition “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.

We have not sold any personal data to third parties for charity/ministry or commercial purposes. We will not sell personal data in the future belonging to website visitors, users, and other consumers.

You may contact us by email at privacy@bridgely.org, by submitting a data subject access request, or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer by email at admin@bridgely.org, or contact us by post at:

Bridgely,

Attn: Heather Neely

15475 Gleneagle Drive

Colorado Springs, CO 80921, USA

Bridgely Safeguarding Policy

INTRODUCTION

International institutions recognize that children and adults at risk (collectively “Vulnerable People”) need special safeguards and care.[1] At OneChild Global, d/b/a Bridgely, we are especially committed to child protection and safeguarding Vulnerable People because of who we are, what we believe and what we do. Under no circumstances should Bridgely in any way contribute to abuse or exploitation or create an opportunity or pathway for new abuse to occur. Because Bridgely interacts with Vulnerable People primarily in the digital realm but works with Partners that have direct contact with Vulnerable People, it is critical that all Bridgely staff, offices and partners implement appropriate measures to safeguard Vulnerable People from the risk associated with digital and personal interactions.

Bridgely’s commitment to zero tolerance for all forms of exploitation and abuse is not merely out of an obligation to comply with legal requirements, although legal compliance is critical. Nor is this motivated solely by pragmatic goals of maintaining the public’s trust, although that is important as well. Rather, this commitment stems primarily from our affirmation of the inherent dignity and worth of every Vulnerable Person as an individual made in the image of God. This policy addresses Bridgely’s commitment to proactively safeguarding and promoting the welfare of Vulnerable People and taking reasonable steps to ensure those who come into contact with Bridgely, or anyone acting on Bridgely’s behalf, do not experience any harm as a result.

This policy provides broad principles guiding how Bridgely employees and others acting in Bridgely’s name, should ensure Vulnerable People are protected. Although Bridgely does not directly engage in field work, Bridgely is acutely aware that safeguarding Vulnerable People is just as difficult in the virtual world as the physical world and that Bridgely’s obligation to Vulnerable People should, and does, extend to its partners who deliver in-person services.

PURPOSE

The purpose of this Policy is to protect Children and Vulnerable People served by Bridgely or otherwise interacting with Bridgely Staff and Partners.

STATEMENT OF POLICY

Bridgely has zero-tolerance for violence, abuse, exploitation and neglect (collectively defined as “Harm”) against Children and Vulnerable People. Harming a Child or Vulnerable Person will result in disciplinary actions and may result in criminal referrals. Bridgely will not knowingly engage – directly or indirectly – anyone who poses a risk to Vulnerable People.

Scope of Policy

This policy applies to all Bridgely Staff and Guests[2]. (These terms encompass a wide variety of people, including employees, supporters, volunteers, Board members, contractors, and partners.)

Local Adaptation

Bridgely owns and operates a digital platform to connect individual supporters with nonprofit organizations and global field partners. Consequently, Bridgely does not engage in direct field activity. Nevertheless, Bridgely requires all its supporters and partners to adopt this Policy, or adopt their own policy with equivalent protections for Children and Vulnerable People. Bridgely encourages others to use and adapt this policy for their local contexts, provided the adaptations meet or exceed those contained in this policy. Proposed local adaptations may be submitted to Bridgely for review. All supporters and partners of Bridgely shall fully support the values and commitments set forth in this Policy, even if the local laws, definitions and terminology, may be slightly different, particularly with respect to reporting.

Bridgely’s Safeguarding Commitments

Bridgely and it’s developer, OneChild Global, commits to taking all reasonable measures to ensure Children and Vulnerable People otherwise impacted by Bridgely’s work are protected as far as possible from harm, including exploitation, neglect and abuse of all kinds.
Bridgely seeks to develop a proactive safeguarding culture within Bridgely that creates and maintains protective environments from recruitment, onboarding, and training of employees, to platform design, and constituent and partner engagement.
Bridgely will carry out appropriate due diligence on partner organizations, which may require ensuring partners have equivalent standards in place or requiring partners to affirm Bridgely’s Safeguarding Policy.
Bridgely will report any credible violations of this Policy or other misconduct related to Children and Vulnerable People, to the OneChild Global Board of Directors, and as required by the governing law of any country where the misconduct occurred.
All Bridgely Staff must be trained in Bridgely’s Safeguarding Policy upon onboarding, and annually thereafter.
Bridgely Staff are expected to treat all Vulnerable People with utmost dignity and care, whether involved in official Bridgely activities or when on personal time off. All Bridgely Staff (at all times, for the duration of their association with Bridgely) and Users and Partners of Bridgely (for the duration of their engagement with Bridgely) must abide by Bridgely’s Safeguarding Code of Conduct.

Bridgely Safeguarding Actions

Bridgely is committed to prioritizing safeguarding in all of our work. We do this in the following ways:

Awareness

Bridgely shall ensure that all Bridgely Staff and Partners receive Bridgely’s Safeguarding Code of Conduct. Bridgely shall further ensure that all Bridgely Staff and Partners understand their obligation to report suspected or known Harm to a Child or Vulnerable Person.

Bridgely’s safeguarding standards shall be communicated to all Bridgely Staff and Partners through the following means: onboarding training, regular and mandatory refresher trainings, job description requirements, performance evaluations, and platform design and implementation. Prior to beginning any employment or engagement with Bridgely, all Bridgely Staff and Partners are required to certify that they have read and will abide by this Safeguarding Policy by signing Appendix B.

Bridgely shall adopt respectful and culturally appropriate communication approaches on safeguarding that are easily understood by Vulnerable People.

Prevention

Bridgely shall implement preventative safeguarding measures, including, but not limited to:

• Screening every candidate for employment and performing background and reference checks to ensure potential hires do not pose a threat to Vulnerable People.

• Requiring all Bridgely Staff, Guests and Partners affirm that they have not harmed Children or Vulnerable People in the past and requiring self-disclosure of any safeguarding incidents which occur.

• Requiring thorough vetting of implementing partners, including requiring equivalent enterprise risk management and safeguarding policies and procedures.

• Conducting an annual risk analysis of the Bridgely platform, implementing additional risk-management measures for high-risk areas and developing action plans to improve safeguarding.

Bridgely Staff shall ensure that all virtual events and activities involving any Children and Vulnerable People are in the best interests of the Children and Vulnerable People.
Bridgely Staff shall protect the rights of Children and Vulnerable People by limiting the amount of personally identifiable information (“PII”) that is shared about Vulnerable People and implementing the necessary security protocols to reasonably protect the PII of Vulnerable People.

Reporting

All Bridgely Staff and Partners shall immediately report any concerns regarding (a) suspected or known harm against Vulnerable People (whether the concerns involve Bridgely Staff and Partners or any other person), (b) suspected or known violations of the Safeguarding Policy or Code of Conduct, or (c) any other inappropriate behavior related to Vulnerable People (a “Safeguarding Report”). Safeguarding Reports should be made to the Bridgely Executive Team. Bridgely’s Whistleblower Policy applies to all Safeguarding Reports made to Bridgely.

All Bridgely Staff and Partners are obligated to make themselves aware of their mandatory reporting requirements and the circumstances under which these obligations arise.
Any person reporting such a concern or allegation should not seek to investigate, but rather report what they know and/or observed. Bridgely will investigate all reports or refer them to the appropriate Bridgely Partner for investigation.

Responding

Bridgely takes allegations of misconduct with respect to Vulnerable People seriously. We will promptly and appropriately investigate Safeguarding Reports.

Bridgely will ensure its internal investigation and adjudicative procedures are safe, timely, consistent, confidential, and fair.
Violations of this policy, including during personal time, shall result in disciplinary actions, determined on a case-by-case basis, up to and including termination of employment, contract, membership on a governing body of an Bridgely entity, or any other form of engagement with Bridgely.
In investigating and responding to complaints, Bridgely will prioritize the needs and privacy of Vulnerable People, consider potential risks for Vulnerable People and their families and take safety precautions as needed to avoid causing any additional harm to Vulnerable People and their families.
Bridgely will share Safeguarding Reports with the Bridgely Global Board of Directors, and as required by local law and by any grant or other agreement.
After a Safeguarding Report is investigated, Bridgely shall take appropriate action through learning, continuous improvement of our policies and procedures, and providing appropriate support to those affected.

Consequences for Violation

Bridgely takes allegations of misconduct with respect to Chidren and Vulnerable People seriously, and will promptly and appropriately investigate reports of violations of this Policy or other misconduct related to Chidren and Vulnerable People. Violations of this policy by Bridgely Staff during time off, will result in disciplinary measures/corrective action determined on a case-by-case basis, which may include training, counseling, warnings and/or termination of employment, contract, membership on a governing body of an Bridgely entity, or other form of engagement with Bridgely. In addition, legal violations covered by this policy may further lead to personal liability and legal/financial consequences.

RESPONSIBILITY

Bridgely’s Co-founders have authority to make changes to this policy. In addition to the formal review, staff can recommend/propose changes, or submit any questions regarding this policy to them.
Co-founders, Scott Todd and Heather Neely, have decision making authority as to exceptions to this policy.

[1] See UN Convention on Rights of the Child.

[2] Guests extend to all volunteers, contractors, suppliers, consultants, and sub-partners engaging in business with Bridgely.