DSPolitical, LLC (“we”, “us”, or “our”) is committed to respecting your privacy rights. Our voter targeted digital ad network and ad targeting technology delivers voter targeted digital ads online and on mobile devices for Democratic and progressive candidates and causes (our “Service”).
DSPolitical, LLC, owner and operator of the Website and the Service, is a limited liability company formed under the laws of the District of Columbia, United States.
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 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 Personal Information
Information You Voluntarily Provide Us: When you visit our Website or use our Service, we may collect certain types of information that you submit voluntarily. You will need a username and password from us in order to access the protected areas of the Website, including the Service. We require some limited information to create an account for you, including your user name, password, email address, mailing address and telephone number. In addition, if you are accessing the Website or our Service on behalf of a Customer, you may provide certain information, for example, the Customer’s name, email address, and password. We also collect certain information from you in order to process transactions on our Service, including credit card numbers and associated billing information. We refer to this information as “Billing Information”. Our legal basis for processing this information is your consent.
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 Website and Service. The Cookie will collect information relating to your use of our Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at our Website and Service via a link from third party site, the URL of the linking page.
In addition to Cookies, our Website 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 Website and Service. Without these Cookies, parts of our Website and Service 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 Website numbers can be analyzed.
Functional – These Cookies are used to remember your preferences on our Website and Service 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 Website and Service, 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 Website, for example, to determine the number of page views and the number of unique users our Website and Service has. We use this information to improve user experience or identify areas of the Website and Service 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 Website and Service
Advertising – Behavioral advertising Cookies, which may be placed on your device by us or our trusted third party service providers, 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 advertising on websites more relevant to you. Although behavioral advertising Cookies can track your activity around the internet, these Cookies cannot identify you personally, even if you are signed in to our Website and Service.
Examples of how we may use advertising Cookies include:
- To market to specific users across our Website and Service and third party sites, so that we and third parties can target advertising to users that will be more relevant to users’ interests.
Third Party Cookies – You may notice on some pages of our Website and Service 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 websites 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 Website and the Service. 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 websites 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 as set forth in the “Contact Us” section below.
Use of Information We Collect
We use the information we collect to respond to your requests, resolve problems, maintain your account and provide our Services to our Customers including to measure or understand the effectiveness of our Services, provide our Website to you, improve our offerings and to create new services, and market our products or services and those of our affiliates, partners and third parties to you.
We may also send you certain Service and administrative notices, which are not subject to opt out.
We use Billing Information only for purposes of authentication and to process transactions on the Service. We may also use information collected above to comply with our legal and regulatory obligations, policies and procedures, and for internal administrative purposes.
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 Service in order to give Customers information in order to evaluate the value of the Service to their needs, as well as to market and improve the Service. We also use aggregate / anonymous data to analyze Website usage and customize the Website’s content, layout and services. These uses improve the Website and the Service and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Website and the Service. 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.
(Disclosing Personal Information to Third Parties)
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.
Aggregated / Anonymous information. In addition, 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 Service in order to give Customers information in order to evaluate the value of the Service to their needs, as well as to market and improve the Service. We also use aggregate / anonymous data to analyze Website usage and customize the Website’s content, layout and services. These uses improve the Website and the Service and better tailor them to meet your needs, so as to provide you with an efficient and customized experience while using the Website and the Service.
Opting Out of Marketing Communications
If you receive marketing or promotional emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “Contact Us” section.
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 Service, 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
(For Audience Members) When acting as a provider of services to our Customers, we have no direct relationship with Audience Members, and any such individuals who seek access, or who seek to correct, amend, or delete their inaccurate 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 to correct or update their Personal Information.
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with 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.
USE OF THIRD PARTY COOKIES
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 Service, 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 Website and the Service are all directed to people who are at least 13 years old or older.
If, for whatever reason, you have any questions, comments, complaints or compliments about the privacy of the Service or this Website, 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: