Shadow Donation

Published by Whole Whale

The six checks

Whole Whale defined the Shadow Donation Page in October 2025. Each clause of that definition is one check, and so is the search harm named in the sentence that follows it. A platform is listed when the evidence shows its pages meet the definition.

  1. 1

    Is the page hosted by someone other than the nonprofit?

    The page lives on the platform’s domain, not the nonprofit’s.

    From the definition: “a third-party, off-domain giving page”

  2. 2

    Did the platform create the page itself?

    The platform built the page, typically from the IRS exempt-organization file, before anyone at the nonprofit touched it.

    From the definition: “auto-generated”

  3. 3

    Did the nonprofit never opt in?

    The page went live without the nonprofit authorizing it. A notice saying the nonprofit has not claimed the page does not change this: disclosure is a mitigation, not an exemption.

    From the definition: “without the nonprofit’s consent”

  4. 4

    Does the page take donations in the nonprofit’s name?

    A visitor can complete a donation on the page, addressed to the nonprofit.

    From the definition: “accepts gifts on the org’s behalf”

  5. 5

    Does the money pass through a fund the nonprofit does not control?

    Gifts are received by an intermediary fund, sponsor, or donor-advised fund that can hold the money, and reassign it if the nonprofit never claims it.

    From the definition: “routing payouts through an intermediary”

  6. 6

    Are the pages exposed to search engines?

    The platform publishes its nonprofit pages to search engines, through a public sitemap and no noindex, so a donor searching for the nonprofit can land on the platform instead of the nonprofit’s own donate page.

    From the definition: “can outrank or confuse results of the official donate page in search”

Four states

  1. Present
    Present, dated evidence

    A dated, hashed evidence bundle shows the platform does this.

  2. Absent
    Absent

    Evidence shows the platform does not do this.

  3. Unresolved
    Unresolved

    Examined, and the evidence does not settle it yet.

  4. Not yet examined
    Not yet examined

    We have not looked. This says nothing about the platform either way.

  5. Present, research only
    Present, research only

    Whole Whale’s published research says the platform does this, but no dated evidence bundle carries it yet. The outline turns solid once a capture backs it, or the mark is withdrawn.

Evidence standard

Every platform we examine gets its own investigation, filed in a dated evidence directory. Once written, an evidence directory is never overwritten. A re-check creates a new one.

  • Anonymous public captures. We fetch pages as any visitor would. We do not create accounts or make donations.
  • Hashed bundles. Each capture keeps its response headers, a UTC capture log, archive.org snapshots, and a SHA-256 checksum file.
  • Screenshots for what a page displays. A claim about what a visitor sees comes from a browser screenshot, never from raw HTML, which can show placeholder values no visitor ever sees.

Absence is not a finding

We reason from evidence, never from silence. A platform missing from this register has not been examined. A check marked not yet examined means only that we have not looked.

Disclosure is a mitigation, not an exemption

Some platforms tell donors that the nonprofit has not claimed the page. That helps, but the page still exists without the nonprofit’s consent, and the platform stays listed.

Platforms can leave the register

A platform that changes what it does is re-examined and moved to the reformed tier, and the change is logged with its date. Charity Navigator moved in September 2026 after it made donations opt-in.

Who examines

Whole Whale examines every platform and publishes the results. We name companies and cite public IRS records. We do not name individual officers, and we do not publish associations we have not verified.

Replies and corrections

A platform named here, or anyone with evidence we have something wrong, can write to letstalk@wholewhale.com. We publish replies and log every correction with its date.