Last Updated: March 11, 2020
Where we collect or receive Personal Information about you directly from you, we will explain the purposes for which we collect and use such Personal Information, the types of third parties to which we disclose that information, and the choices and means, if any, we offer you for limiting the use and disclosure of Personal Information about you. This explanation will be provided as soon as practicable and, in any event, before we disclose your Personal Information or use such information for a purpose materially different than that for which it was originally collected or processed.
Where we collect or receive Personal Information about you from our Customers, which occurs when we are acting as a provider of services to our Customers, we do so as a processor (under the GDPR) and/or service provider (under the CCPA) of Personal Information on behalf of our Customers. We will use such information in accordance with the notices provided by our Customers and in accordance with the choices you made with respect to such Personal Information, as communicated to us by our Customers.
Collection of Information
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information when you fill out a form, make a donation, send us an email, sign up to receive email updates, sign a petition, sign up as a volunteer, create an account, schedule an event, participate in a contest or promotion, make a purchase or contribution, communicate with us via third party social media sites, request information, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, mobile number, credit card information and other contact or identifying information you choose to provide. Our legal basis for processing this information is your consent.
Information We Collect Automatically When You Use the Site and Services
When you access or use our Site and Services, we automatically collect information about you, including:
We log information about your use of the Site and Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Site.
We may collect information about the computer or mobile device you use to access our Site and Services, including the hardware model, operating system and version, device identifiers and mobile network information.
INFORMATION COLLECTED BY COOKIES AND OTHER TRACKING TECHNOLOGIES:
Our legal basis for processing this information is your consent and our legitimate interests, namely monitoring and improving our Site and Services.
Information We Collect From Other Sources
We may also obtain information from other sources and combine that with information we collect through our Site and Services. For example, we may receive publicly available voter file data from our Customers, and we may use such information for list matching purposes. Our legal basis for processing this information is our legitimate interests, namely monitoring and improving our Services, and the legitimate interests of our Customers (data controller under GDPR and/or business under CCPA).
Use of Information
We may use information about you for various purposes, including to:
- Provide, maintain and improve our Site and Services;
- Provide and deliver the information you request, process contributions and transactions and send you related information, including confirmations and invoices,
- Send you confirmations, technical notices, updates, security alerts and support and administrative messages;
- Request feedback and to otherwise contact you about your use of the Site and Services;
- Respond to your comments, questions and requests and provide customer service;
- Send you newsletters and otherwise provide you with information or services you request or that we think will be of interest to you, such as sending you information to keep you informed about various issues, events, resources, promotions, contests, products and services;
- Help connect you with other supporters, and to solicit volunteers for issues and organizations that we support;
- Monitor and analyze trends, usage and activities in connection with our Site and Services;
- Personalize and improve the Site and Services and provide advertisements, content or features that match user profiles or interests;
- Process and deliver contest entries and rewards;
- Link or combine with information we get from others to help understand your needs and provide you with better service; and
- Carry out any other purpose for which the information was collected.
Aggregated / Anonymous information. We may use information that is in aggregate / anonymous form to create compilations of aggregated data and/or statistics and reports, and any other uses without restriction. This includes reporting information to Customers of the Site and Services in order to give Customers information in order to evaluate the value of the Site and Services to their needs, as well as to market and improve the Site and Services. We also use aggregate / anonymous data to analyze Site and Services’ usage and customize their content, layout and services. These uses improve the Site and Services and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Site and Services. Information that is in “aggregate / anonymous” form refers to non-identified information or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person), and does not include information as to which identifying characteristics have been removed without means reasonably likely to be used by any person to re-identify the natural person directly or indirectly.
The Company is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Site or Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.
Sharing of Information
- With vendors, consultants and other service providers who need access to such information to carry out work on our behalf in order to provide the Site;
- In response to a request for information if we believe in good faith disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;
- If we believe in good faith sharing is necessary to resolve disputes, investigate problems or enforce our user agreements or policies, or to protect the rights, property and safety of the Company, its employees, volunteers, or others;
- In connection with, or during negotiations of, any reorganization, formation of new organization, asset sale or transfer, financing or lending transaction or in any other situation where personal information may be disclosed or transferred as one of the assets of the Company; and
- With your consent or at your direction, including if we notify you through our Site or Services that the information you provide will be shared in a particular manner and you provide such information.
We will offer you the opportunity to choose whether your Personal Information is to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by you.
We may share aggregated or anonymized information that does not directly identify you without restriction.
Social Sharing Features
The Site and Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Site or Services with other media, and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Advertising and Analytics Services Provided by Third Parties
For more information about Internet-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.networkadvertising.org/managing/opt_out.asp and
You may opt out of receiving updates and newsletters from the Company by following the instructions in those emails or by emailing us by clicking here. If you opt out, we may still send you other types of administrative emails, such as those about your use of the Site or Services or any donations or transactions.
ACCOUNTABILITY FOR ONWARD TRANSFER
We use model contractual clauses and other mechanisms approved by the European Union and Switzerland, respectively, for transfers of Personal Information from the European Economic Area (“EEA”) and Switzerland.
DATA INTEGRITY AND PURPOSE LIMITATION
We endeavor to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the Individual. We will take reasonable steps designed to ensure that only Personal Information that is relevant to its intended use, accurate, complete, current, and otherwise reliable in relation to the purposes for which the information was obtained is used by us for as long as we retain possession of such information. Our personnel have a responsibility to assist us in maintaining accurate, complete and current Personal Information. When acting as a provider of services to our Customers, we endeavor only to process Personal Information that is relevant to our Services, and for purposes compatible with those for which the Personal Information was collected; wherever possible, such Personal Information is non-identified.
ACCESSING AND CONTROLLING YOUR INFORMATION
EU data protection law makes a distinction between organizations that process Personal Information for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). If you have a question or complaint about how your Personal Information is handled, these should always be directed to the relevant controller, since the controller has primary responsibility for your Personal Information.
(For Voters) When acting as a provider of services to our Customers, we have no direct relationship with Voters, and any such individuals who seek access, or who seek to correct, amend, delete, or restrict processing of their Personal Information should direct their inquiries to the relevant Customer which has transferred such Personal Information to us for processing. We will assist our Customers in fulfilling their obligations under applicable law to respond to such requests by individuals regarding their Personal Information.
Please note that while any deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Information for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
RECOURSE, ENFORCEMENT AND LIABILITY
We encourage you to raise questions about our processing or disclosure of your Personal Information by contacting us, as set forth in the “Contact Us” section below.
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. Taking into account the risks involved in the processing and the nature of the information we process, we maintain appropriate administrative, technical and physical safeguards to protect information in our possession against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing. This includes, for example, firewalls, password protection, encryption and other access and authentication controls.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Site and Services, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your information has been compromised, please contact us as set forth in the “Contact Us” section below.
We have a security incident response program designed to promptly respond to and escalate any potential privacy or security incident. If we learn of a security incident, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
In compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our Site and Services are all directed to people who are at least 13 years old or older.
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Supplemental Privacy Notice for California Residents
INFORMATION WE COLLECT
Our Site and our Services collect Personal Information. In particular, our Site and our Services have collected the following categories of Personal Information from consumers within the last twelve (12) months:
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, including:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of Personal Information listed above from the following sources:
- Directly from our Customers or their agents. For example, from documents that our Customers provide to us related to the Services for which they engage us.
- Indirectly from our Customers (or their agents) through our Customers’ use of our Services, including data we collect from our Customers about Visitors’ use of our Services.
- Directly and indirectly from activity on our Site. For example, from your communications submitted through our Site’s portals, billing information you provide to us, or Site usage details collected automatically.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our Site and our Services and present their contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our customers or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
SHARING PERSONAL INFORMATION
We may disclose your Personal Information to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
Categories A [Identifiers], B [Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))] and I [Professional or employment-related information]:
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Our service providers.
In the preceding twelve (12) months, we have not sold any Personal Information within the meaning of “sale” under the CCPA.
YOUR RIGHTS AND CHOICES
The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and verify your request, we will disclose to you:
- The categories of Personal Information we have collected about you.
- The categories of sources for the Personal Information we have collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- (Applicable if we sell or disclose your Personal Information for a business purpose) Two separate lists disclosing:
- Sales, identifying the Personal Information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at (202) 888-7783
- Emailing us at [email protected]
- Visiting https://www.risingtideinteractive.com/
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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If, for whatever reason, you have any questions, comments, complaints or compliments about the privacy of the Site and Services, please contact our email support. Please also use this email address if you believe you have received a marketing communication from us that you feel makes use of your information in an unauthorized or unwelcome way. Please contact us using the information below:
1250 H Street NW, Suite 200
Washington, DC 20005 USA
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What are Cookies?
A Cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Site and Services. The Cookie will collect information relating to your use of our Site and Services, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at our Site and Services via a link from third party site, the URL of the linking page.
In addition to Cookies, our Site and Services and email marketing communications may use web beacons. A web beacon, also known as a tracking pixel, is a line of code which is used by a website or email marketing communications or, less frequently, a third party ad server to measure a user’s activity, such as interaction with an advertisement or purchase of a service or product, and to validate user engagement with advertisements for purposes of facilitating future advertising. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF.
WHAT ARE THE DIFFERENT TYPES OF COOKIES AND HOW DO WE USE THEM?
Essential – These are Cookies which are essential for the running of our Site and Services. Without these Cookies, parts of our Site and Services would not function. These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.
Examples of how we may use essential Cookies include:
- Setting unique identifiers for each unique visitor, so that Site numbers can be analyzed.
Functional – These Cookies are used to remember your preferences on our Site and Services and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally. Functional Cookies do not track your internet usage or gather information which could be used for selling advertising.
Examples of how we may use functional Cookies include:
- Gathering data about visits to our Site and Services, including numbers of visitors and visits, length of time spent on the site, pages clicked on or where visitors have come from
- Eliminating the need for returning users to re-enter their login details.
Analytical Performance – Analytical performance Cookies are used to monitor the performance of our Site and Services, for example, to determine the number of page views and the number of unique users our Site have. We use this information to improve user experience or identify areas of the Site and Services which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.
Examples of how we may use analytical Cookies include:
- Measuring users’ behavior
- Analyze which pages are viewed and how long for and which links are followed to better develop our Site and Services
Advertising – In providing our Services to our Customers, we or our Behavioral advertising Cookies, which may be placed on your device by our trusted third party service providers use behavioral advertising Cookies, which may be placed on your device by our trusted third party service providers in order to remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make our Customers’ advertising more relevant to you. Although behavioral advertising Cookies can track your activity around the internet, these Cookies cannot identify you personally.
Third Party Cookies – You may notice on some pages of our Site and Services that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own Cookies on your device. We do not control the use of these third party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third party webSite for more information about these Cookies.
HOW CAN YOU MANAGE OR OPT OUT OF COOKIES?
Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site, but block them from third parties. In others, you can block Cookies from specific advertisers, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Site and Services. To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.
Opting out of Analytical Performance Cookies
If you would like to opt out of Analytics Cookies, please do so by clicking on the links below:
Google Analytics – https://tools.google.com/dlpage/gaoptout
Opting out of Behavioral Advertising Cookies
If you would like to opt out of Behavioral Advertising Cookies placed by us or our trusted-third party service providers, please do so by clicking on the links below:
Facebook – https://www.facebook.com/policies/cookies/
The Trade Desk – https://www.adsrvr.org/
Twitter – https://twitter.com/en/privacy
Opting out of Third Party Cookies
If you would like to disable “third party” Cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to the third party’s website and getting them to generate a one-time “no thanks” Cookie that will stop any further Cookies being written to your machine. The online advertising industry provides webSite from which you may opt out of interest-based advertising from other companies that participate in industry self-regulatory programs. The US-based opt out pages are www.aboutads.info/choices and www.networkadvertising.org/choices. The European based page is www.youronlinechoices.com.
Further Information and Contact Details
If you have any questions about or if you would like more information on the Cookies that we use and their purposes, please contact us at:
1250 H Street NW, Suite 200
Washington, DC 20005 USA