Privacy Policy, Terms of Service, and Data Usage Agreement

Last updated: March 15, 2024

This Privacy Policy, Terms of Services  and  Data Usage Agreement (collectively “Privacy Policy”) describes Our (Voter.Vote, Inc. or “Our” or “Us”) policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

By visiting the Website, accessing Our services (“Services”), or doing business with Us, you are accepting the practices described in this privacy policy and expressly consent to the use and potential disclosure of your Personal Data in accordance with this Privacy Policy. If you disagree, disapprove, or do not wish to comply with this Privacy Policy, please immediately discontinue visiting our website and using our Services. 

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy is intended to clearly explain what we consider to be “personal data,” what we consider to be “anonymous data,” and how this information is collected, used, and disclosed by Us.  

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Voter.Vote, Inc., 1259 El Camino Real #500, Menlo Park, CA 94025.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: California, United States
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website, use of our Data and the like.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Voter Vote (and any and all other affiliate websites or related websites).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

We provides voter data products and services to political organizations, operates Software-as-a-Service (SaaS) subscription services, software applications, voter data files and other services through our website (or through mobile apps or other means) products and services (all of such software applications and services the “Services”)

In the process of doing business and providing the Services, We collects and maintains information classified as both “Personal Data” and “Anonymous Data” using the following definitions:

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data
• Voter registration information we provide you through use of the Services, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by, or through, a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google
• Facebook
• Instagram
• Twitter
• LinkedIn
• Others

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Voter Information

Voter Information or Voter File Data. Some of the Services provides voter data derived from government agencies to organizations permitted to use voter data under state or local law. Access to voter data is limited in how it may be used as well as the duration under the applicable purpose. Under no condition is access to voter data ever granted in perpetuity. Exact voter data fields vary from state to state. They commonly include Name, Address, Birth Date, Gender, Party, Phone Number, and Email Address as provided by individuals on their voter registration forms. We have no authority to provide voter data or permit the use of voter data beyond the scope of applicable state or local law. We do not make any changes to voter data that could possibly impact a voter’s eligibility or status. We do not have the authority to add or remove voters on behalf of any government elections agency. It is the responsibility of individuals using Our voter data to determine whether their use of the data is legally permissible. Voter data may never be used for personal or commercial use. Traditional political campaign methods often require the exporting of paper or electronic lists which can be provided by the Services. The organization purchasing the list or software subscription is responsible for protecting the privacy of individuals contained on such lists or files. All lists and electronic files that you obtain through use of the Services should be stored with personal privacy in mind and destroyed immediately after using. We ask that all users of the Services maintain and store these lists and files with a respectful consideration of the personal privacy of the individuals contained on these lists and files. Please treat these lists and files as if your personal information is included.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies on the Free Privacy Policy website article.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

  Type: Session Cookies

  Administered by: Us

  Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

  Type: Persistent Cookies

  Administered by: Us

  Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service. This includes monitoring the usage of our Service.
• To manage Your Account. This includes your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract. The development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You. To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with Insights. To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests. To attend and manage Your requests to Us.
• For business transfers. We may use Your information 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 Data held by Us about our Service users is among the assets transferred.
• For other purposes. We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers. We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers. We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates. We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners. We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users. When You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• With Your consent. We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing into Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: info@voter.vote
• By visiting this page on our website: http://www.voter.vote/contact-us
• By mail: 1259 El Camino Real #500, Menlo Park, CA 94025

California Consumer Privacy Act – CCPA (Effective January 1st, 2020)

The CCPA, was passed by the California State Legislature in AB375 in 2018 and signed by the Governor that year. Subsequent legislation AB25, AB874, AB1146, AB1355 and AB1564 made modifications to the law. The total of these legislative protections take effect on January 1, 2020.  The CCPA places important protections on commercial use of personal data collected by entities doing business in California. It allows consumers to view any data collected on them, restrict use of that data and even have their data deleted under most circumstances.

We are required to comply with the CCPA for data that is acquired from our public website (Voter.Vote) and sales process. We is not required to comply with the CCPA for Personal Data associated with registered voters. Any adherence to the CCPA with regard to Personal Data associated with registered voters would be strictly voluntary and conditional. Please continue reading this section for more specific details.

The law creates two important exemptions for those working within areas of political free speech, governmental, and legitimate research. These can be found in two key sections of the new law:

• Cal. Civ. Code § 1798.105 (d) (4) A business or a service provider shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for the business or service provider to maintain the consumer’s personal information in order to exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Cal. Civ. Code § 1798.140 (f) For purposes of this title: “Commercial purposes” means to advance a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction. “Commercial purposes” do not include for the purpose of engaging in speech that state or federal courts have recognized as noncommercial speech, including political speech and journalism.

Amendments to the law in 2019 went further in three areas that provide additional protections for Our clients that use data that we provide as part of our Services. These amendments to the law provide that data legally made available from federal, state or local governments is excluded from the provisions which apply to “personal information.” (Civil Code Section 1798.140 (O) (2)). These amendments further clarified that data such as voter files, political donor data, and other data commonly used by Our is not subject to the provisions.

These amendments also provided greater clarity by defining “personal information” in a way that exempts de- identified or aggregate consumer data. (California Civil Code Section 1798.145 (a) (5)) This is the kind of data utilized by Us in modeling and other voter targeting, and the amendment expressly excludes this data from the consumer protections under this law.

California Privacy Rights

California residents, in addition to the above Privacy Rights, are also entitled to certain additional information and have certain additional rights under the California Consumer Privacy Act (“CCPA”) as stated below.

Information We Collect and How We Use It

Below is a summary of our collection and use of “personal information” (as defined by the CCPA) about Consumers in connection with our Services. For additional details, please consult the other sections of this Privacy Notice. 

Categories of personal information we may collect and use for our commercial and business purposes:

• Contact and account registration information. When you register for an account or contact us you may provide your name, email address, physical address, phone number, account username and password, electronic signature, and other related information.
• Financial or payment information. We collect information about payment methods that you provide, billing information, and information about the Services you subscribe for purchase.
• User information. When you use the Services, we may collect names and email addresses of parties using the Services and personal information about those individuals or their devices, such as name, email address, IP address, and authentication methods.
• Customer communications. We collect information about your customer service communications with us, including, for example, questions and other messages you address to us directly through online forms, by email, over the phone, or by post.
• Information about your web browser, mobile device, or internet connection. When you access our Services online, we may automatically collect IP address, device identifiers and device attributes, including cookie IDs, mobile advertising IDs, and other similar unique identifiers, data about how you interact with the Services online (usage data), location information (e.g., city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation) and, with your permission in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile device.
Purposes for which we use the personal information we collect:
• Provide you with and collect payment for the Services you request.
• Create your account and communicate with you.
• Market our Services by sending you emails.
• Test changes in our Services and develop new features and products.
• Fix problems you may have with our Services, including answering support questions and resolving disputes.
• Manage the Services platform including support systems and security.
• Prevent, investigate and respond to: fraud, unauthorized access to or use of our Services, breaches of terms of use and policies, or other wrongful behavior.
• Comply with legal obligations.
• Meet legal retention periods.
• Establish, exercise, or defend our rights in legal claims.

The Right to Opt Out of Sales of Personal Information

Consumers have the right to opt out of “sales” of their personal information under the CCPA.

1. General Opt-Out Rights: If you do not wish for Voter.Vote, Inc. to use or share your personal information in the ways described in this Privacy Policy, you have the right to opt-out. Depending on the nature of the information and its use, the procedures for opting out may vary. Below are the methods by which you can exercise your opt-out rights.

2. Email Communications: If you no longer wish to receive certain email communications from us, you can remove yourself at any time by clicking on the “unsubscribe” link located at the bottom of our emails. Please note that even if you opt-out of receiving promotional communications, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

3. Targeted Advertising: If you do not wish to participate in our ad-customization programs, you can opt-out by following the instructions provided by our third-party advertising partners, typically available through their privacy policy or directly on the advertisements themselves. Please be aware that this does not prevent you from seeing advertisements; it merely means the advertisements will not be tailored to your interests.

4. Data Sharing: If you would like to prevent Voter.Vote, Inc. from sharing your personal information with third parties for marketing purposes, please contact us at info@voter.vote with the subject line “Data Sharing Opt-Out.”

5. Cookies and Tracking: Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our website. Additionally, many advertising networks offer a way to opt out of targeted advertising. For more information, visit [www.aboutads.info/choices] or [www.youronlinechoices.eu].

6. California Residents: If you are a resident of California, you may have additional rights to opt-out of the sale of your personal information. Please see the “California Privacy Rights” section for more information.

7. Changes to Your Personal Information: You can review and change your personal information by logging into the website and visiting your account profile page. If you have questions about modifying or deleting your personal data, please contact us at info#aaaa.

8. Contact Us: If you have any questions or concerns regarding your opt-out rights or our data practices, please contact us at:

   • By email: info@voter.vote
   • By visiting this page on our website: http://www.voter.vote/contact-us
   • By mail: 1259 El Camino Real #500, Menlo Park, CA 94025

No Sale of Personal Information

In the preceding twelve (12) months, We have not sold and will not sell any personal information to nonaffiliated third parties without your consent. We, also, have not and will not sell the personal information of minors under 16 years of age to non-affiliated third parties without affirmative authorization.

Right to Know About Personal Information Collected, Used, or Disclosed

You have the right to request that we disclose certain information to You about our collection, use and disclosure of Your Information over the past 12 months. Once we receive Your request and verify Your identity, We will disclose to You: (1) the categories of Information We collected about You; (2) the categories of sources for the Information; (3) Our business or commercial purpose for collecting or disclosing that Information; (4) the categories of third parties with whom We shared that Information; and (5) the specific pieces of Information We collected about You in the preceding 12 months.

Right to Delete Personal Information Collected or Maintained

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 request and verify Your identity, We will permanently delete (and direct our service providers to delete) Your personal information from Our records, unless a legal exception to deletion applies. In Our response to Your request to delete, We will specify the manner in which We have deleted Your personal information or, if We must deny Your deletion request, the basis for this refusal.

Right to Non-Discrimination for Exercise of Privacy Rights

We will not discriminate against You for exercising any of Your rights by: (a) denying You goods or services; (b) charging You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (c) providing You a different level or quality of goods or services; or (d) suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request to Us by either:

• By email: info @ voter.vote
• By visiting this page on Our website: http://www.voter.vote/contact-us
• By mail: 1259 El Camino Real #500, Menlo Park, CA 94025

Authorizing an Agent

You may designate an authorized agent to submit Your consumer request on Your behalf, so long the authorized agent has Your written permission to do so and You have taken steps to verify Your identity directly with Us.

Verifying Your Request

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 Your identity or authority to make the request. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

To verify your identity, We ask that You to provide Us with the following information when You submit Your request: (1) first name, (2) last name, and (3) phone number or email. We will use the above information to verify Your identity.

Depending on Your type of request or the information requested by You, We may require additional information to verify Your identity and fulfill Your request. 

California law also requires that We disclose how We respond to “do-not-track requests” from Our users. At this time, We do not currently respond to “do-not-track” requests from Our users’ browsers.

“Shine the Light”

California residents may ask for a list of third parties that have received Your personal information for direct marketing purposes during the previous calendar year. This list also contains the types of personal information shared. We provide this list at no cost. If You are a California resident and would like to request this information, please contact Us at info @ Voter.Vote.