Digital Fundraising

If you are a nonprofit, there are a growing list of sites that are currently using Shadow Donation Pages to solicit funds from donors in your name and that is somehow legal under First-Amendment protected speech (Riley v. National Federation of the Blind 1988).

Shadow Donation Page (n.)
A third-party, off-domain giving page that was auto-generated without the nonprofit’s consent, that accepts gifts on the org’s behalf while routing payouts through an intermediary. Some Shadow Donation Pages can outrank or confuse results of the official donate page in search, and “no platform fee” flows frequently lead to optional (sometimes preselected) tips or add-on donations to the gatekeeper. Credit card processing fees are not covered by these solutions.

Term coined by Whole Whale October, 2025

When are Shadow Pages not *shady?

• Net-new money. Proven to expand giving, not cannibalize existing channels.
• SEO restraint. Don’t outrank the nonprofit’s own donate page; de-index unclaimed pages.
• Friction down, not up. Faster checkout, fewer clicks, no dark patterns.
• Data back to the org. Pass donor contact + consented prefs, not just dollars.
• Permission or easy exit. Ask first when possible; otherwise clear, 1-click opt-out.
• Clear labeling. “Hosted by X, funds regranted via Y” front and center. No brand confusion.
• Fee transparency. Show total take-rate before payment. Tips off by default.
• Payout reliability. Defined payout windows (e.g., 15–45 days) and failure handling.
• Security & compliance. PCI-compliant, anti-fraud, and follows state/DAF rules.
• Data portability. Exportable in common formats; easy to switch vendors.

Non-negotiables (deal breakers)

• Hoarding donor emails or hiding consent terms.
• Hijacking branded queries (“donate to {ORG}”) with your page.
• Forced tips or surprise fees.
• No opt-out, slow takedowns, or shadow relisting.

“Shadow Donation Pages are shady if a donor can’t tell who’s charging what, where their data goes, and how to give on the org’s site instead – it is shady.” – George Weiner, Chief Whaler, Whole Whale

List of Shadow Donation Page Platforms

How to read this: The table summarizes SEO strength and potential risks if unmanaged—while also noting what each platform does well. Use it to prioritize where to claim, optimize, or remove.

Platform Snapshots (For Quick Due Diligence)

• Every.org. 501(c)(3) regrantor model; 0% platform fee, optional donor tip; nonprofits can claim profiles and manage info. (Every.org)
• PayPal Giving Fund (PPGF). Massive U.S. charity directory used across partners (PayPal app/site, eBay, Meta). PPGF itself doesn’t charge fees on PayPal surfaces; partner flows may involve processor fees and PPGF payout timelines. (PayPal)
• Charity Navigator – Giving Basket (Give Lively). Donors can give to many orgs in one checkout and control what data they share; fees documented by Give Lively. (Charity Navigator)
• Meta/Facebook charitable giving (via PPGF). Donate buttons/fundraisers route through PPGF; typical payout windows 15–45 days (enrolled) or ~90 days (unenrolled). (TechSoup Blog)
• GreatNonprofits. Reviews + nonprofit profiles with Donate buttons; donations route via PPGF with posted processing fees and payout timing. (aboutgreatnonprofits)
• GiveFreely. Browser extension/commerce model that donates commissions to a chosen charity; public charity directory available. (Give Freely)
• Pledge (Pledgeling). Directory + instant fundraisers; regrants via Pledgeling Foundation; published $5 per disbursement fee policy and other details. (Pledgeling Foundation)

A Brief and Mostly Complete Shadow Donation Page History

1999 — Helping.org (AOL Foundation): First big “give to any charity” portal (via GuideStar). Not exactly mass profile pages, but it seeded the model. The Washington Post

2001 — Network for Good (now Bonterra NFG / “For Good”): Absorbed Helping.org; any-charity giving rails that later powered lots of third-party “Donate” buttons. Wikipedia

2003 — eBay Giving Works (MissionFish → PayPal Giving Fund): Charity directory baked into eBay; evolved into PayPal Giving Fund (PPGF) as a donations DAF + directory. WIRED+2ebayinc.com+2

2008 — GuideStar adds “Donate Now” on profiles (site-wide buttons = de facto donation pages for every listed org). Powered via partners; this is one of the earliest true mass profile→donate patterns. Chronicle of Philanthropy

2009 — GiveMN (statewide directory): Launch included pages for thousands of Minnesota orgs; a template for state/NPO directories that seed org pages by default. GiveMN+1

2013–2023 — AmazonSmile: Auto-generated charity selection pages tied to IRS data; sunset in Feb 2023. AP News+1

2015 — Charity Navigator “Giving Basket”: Unified checkout to any charity; not a browsable page per org at first, but a broad donation rail that underpins profile→donate UX. Charity Navigator+1

2015 — Facebook Fundraisers / Donate button: Scaled donate flows living on org/user pages; more opt-in than auto-generated, but pivotal for platform-hosted giving. Facebook+1

2016+ — PayPal Giving Fund directory: Large, PPGF-hosted charity directory; processes gifts and grants to enrolled and (slower) unenrolled orgs—functionally “pages for (almost) all.” PayPal

2007→now — GreatNonprofits: Auto-lists IRS-recognized orgs and slaps a Donate button on unclaimed profiles (donations flow via PPGF). Classic auto-page example. GreatNonprofits+1

2020s — Every.org: Maintains profiles for most 501(c)(3)s by default; nonprofits can later claim/edit—again, auto-generated page pattern. support.every.org+1

2025 — GoFundMe’s 1.4M pages (reversed to opt-in): Auto-generated nonprofit pages from IRS/partner feeds; after backlash, promised de-indexing and opt-in only. Peak “shadow page,” then retreat. ABC7 San Francisco+2ABC7 San Francisco+2

Cool, what should we do about it?

Big Picture:
This is a growing problem as more toll collectors show up with Shadow Donation Pages. Every startup with even the best intentions of <sarcasm>finally providing 0 fee innovation</sarcasm>, is simply creating yet another place where nonprofits need to manage a profile and probably pay a fee for integrations to their data systems.

Truth is, if there is money to be made collecting tolls on these Shadow Donation Pages organizations, both for-profit and nonprofit, will keep doing it #capitalism.

The Bad News: (using bullets b/c there’s a lot of it, sry but you chose to read this)

• AI vibe coding is going to create a wave of new startups that are going to rip and use this IRS 990 data to “finally fix donations” and insert themselves as a toll collector.
• This rise of pages will create more brand cleanup work for nonprofits (details below on how to Claim, Control, and Kill these pages.
• AI is scraping and ingesting all of this content as another point in your AI Brand Footprint.
• This outdated data from old IRS 990s is getting pumped out at scale. This fragmented system of donation pages may lead to confusion in
• As donors move to AI-first interactions, there will be a player that *wins* the right to route these donations (probably PPGF) to nonprofits directly from the chat platform. AKA the ultimate Shadow Donation Page.

Example of what it looks like when AI ingests Shadow Donation Pages:

The Good News:
Many of these players are going to get mowed down by AI crushing the organic traffic of these Shadow Donation Pages. Once the toll booth money dries up and the work to keep up with takedown notices piles up, the social impact tech tourists will move on to the next hot thing.

Also, Whole Whale is working on a moonshot idea that has a 1% chance of making this less terrible called the Verified Giving Protocol.

Claim, Control and/or Kill

Claim: All platforms *usually* have a way to create an account and gain access to your data at a free level. Control: Once verified as an agent of the organization, the platform will let you update key information that may be outdated because it was ripped from old IRS 990s.
Kill (option 1): From there you should also be able to request to remove or hide the page if you feel it isn’t additive to your donation and reputation strategy.

Kill (option 2) : Where to submit Takedown Notice

• Find the platform’s Privacy, Terms, or Legal page → look for “Report,” “Takedown,” “Trademark,” “Abuse,” or a legal@/support@ email.
• If in doubt, submit via both the form and email.

Yeah, this info is buried farther down than a page 2 Google Search result but it is there…

What to include (non-negotiable)

• Full legal nonprofit name + EIN
• Authority statement (you represent the org)
• URLs of all unauthorized pages (and any vanity/SEO variants)
• Explicit request to remove, delist, and de-index all pages using your name
• Phrases to use: “unauthorized charitable solicitation”, “brand misuse”

If you’re in California

• Cite California Government Code §12599.9 (platforms must verify charities before listing).
• Add: “This page appears non-compliant with §12599.9 verification requirements.”

Evidence to attach (helps)

• Screenshot(s) of the page(s)
• Proof of your official donate page URL
• Trademark registration (if you have it) or proof of longstanding use

Follow-up cadence

• If no action in 5 business days, reply once.
• If still nothing in 10 business days, file with the state AG/charitable regulator and copy the platform.

Template Take Down Notice Email *NOT LEGAL ADVICE*

(also, we both know you are just going to copy and paste this into your AI tool…)

Subject: Takedown Request — Unauthorized Charitable Solicitation & Brand Misuse ([ORG NAME], EIN [EIN])

Hi Legal/Support Team,

I’m contacting you on behalf of [Full Legal Nonprofit Name] (EIN [EIN]). I am [Title] and authorized to act for the organization.

Your platform is hosting pages using our name that we did not create or authorize, constituting unauthorized charitable solicitation and brand misuse. Please remove, delist, and de-index the following pages immediately:

[URL 1]

[URL 2]

[Add others]

Our official donation page is: [official donate URL].
These unauthorized pages create donor confusion, interfere with stewardship, and misrepresent our brand.

If you require verification, reply to this email and I’ll provide any additional documents needed.

California organizations: Please note California Government Code §12599.9 requires fundraising platforms to verify charities before listing them. The pages above appear to be listed without such verification and should be taken down.

Requested actions (within 5 business days):

Remove the pages from public view

Block re-creation of pages using our name without written authorization

Confirm de-indexing with search engines (returning a 404/410 or proper noindex)

Provide written confirmation of completion

Thank you,
[Name]
[Title], [Org]
[Email] | [Phone]
[Org Address]

FAQ