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”).

We created this Privacy Policy (“Privacy Policy”) in order to demonstrate our commitment to you (“you” or “your”), our Customers, Visitors and Audience Members (all defined below), regarding your privacy with respect to information that we collect about you or that you submit to Us via the Service or through our internet website located at http://www.DSPolitical.com (the “Website”).

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.

This Privacy Policy applies to our “Customers”, who are Democratic and progressive candidates and causes that use our Service and individuals acting on behalf of such Customers; to “Visitors”, who are visitors to our Website and may include Customers; and to “Audience Members”, who are actual or potential voters about whom we receive Personal Information from our Customers when We are acting as a provider of the Service to our Customers.

This Privacy Policy does not apply to information of any kind that we collect by means (including offline means) or from sources other than those specified herein.

PERSONAL INFORMATION

As used in this Privacy Policy, “Personal Information” means any information or set of information about an identified or identifiable natural person, where an identifiable natural person is one who can be identified by all means reasonably likely to be used by any person to identify the natural person directly or indirectly.  “Personal Information” does not include information that is not associated with an identified or identifiable individual 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.

NOTICE

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.

Information We Collect From Third Parties: We may also acquire information about Audience Members from third parties, including from our Customers and other trusted sources. This information may include name, email address, mailing address and telephone number, as well as demographic and voting data to supplement this information. Those third parties have privacy policies that may differ from this Privacy Policy. We do not control the data privacy or protection policies of third parties, and we are not responsible for the privacy practices of these third parties.  Our legal basis for processing this information is our legitimate interests, namely monitoring and improving our Service, and the legitimate interests of our Customers (data controller).

Automatically-Collected Information: Whether you are a Visitor visiting our Website or acting on behalf of a Customer visiting our Website, we automatically collect certain information that your browser sends when visiting websites in general. This information, often referred to as “Log File Information”, may include the URLs you visited; your IP address; date and time when visiting our Website and time spent on pages visited; and information about your browser and platform. In addition, when you use the protected areas of the Website, certain Log File Information about your use is automatically recorded and retained, such as account activity (e.g. number of log-ins), and data displayed or clicked on (e.g. user interface elements, links).  This information may also include Cookies, web bugs, device information, and navigational data like Uniform Resource Locators (URLs), which we may use to gather information regarding the date and time of your visit, as well as your geo-location (from your IP address).  “Cookies” are small pieces of information that a website sends to your browser. Session 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.  Session Cookies are only stored for the duration of your visit to the Website and are deleted from your device when you close your browser.  Persistent Cookies are saved on your device for a fixed period of time after you close your browser and are activated each time you visit our Website.  Persistent Cookies can be removed by following your Internet browser help file directions. If you choose to disable persistent Cookies, you may experience session errors and may need to log-in again each time you use the Service.  Our legal basis for processing this information is your consent and our legitimate interests, namely monitoring and improving our Website and Service.

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.

Cookies and Log File Information. We use Cookies, other identification technologies and Log File Information to provide personalized content and to administer and monitor usage of the Service and Website. We also use Cookies, other identification technologies and Log File Information to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

CHOICE

(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.

General. We may disclose your information: To third party vendors or service providers who help us provide the Service or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request; To third parties to whom you ask us to send your information; To a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), provided that we require our Affiliates to honor this Privacy Policy; To a company that merges with us, acquires us, or purchases our assets, in which case such company may continue to process your information as set forth in this Privacy Policy; or If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Customer contracts; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us; or (c) protect and defend our rights or property or the rights and property of you or third parties; or (d) to prevent physical harm to an individual or financial loss.

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

The Website is hosted and the Service is provided in the United States of America. In the performance of our Service and business operations, Personal Information we collect or receive may be stored or transferred internationally throughout our organization and to our service providers or agents, in accordance with applicable data privacy laws.  Transfers to third parties are covered by the provisions in this Privacy Policy under Notice and Choice.

We will endeavor to obtain assurances that any such service provider or agent will provide at least the same level of privacy protection as is required by this Privacy Policy and will notify us if it makes a determination it can no longer meet this obligation.

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.

Where we know that any third party to whom we have provided Personal Information is using or disclosing Personal Information in a manner contrary to this Privacy Policy, we will take reasonable steps to prevent or stop the use or disclosure. With respect to such onward transfers to agents, and to the extent we are responsible for the event, we will remain liable should our agents process Personal Information in a manner inconsistent with this Privacy Policy.

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.

(For Customers and other Visitors to Our Website) Under laws in certain countries in which we operate, Customers and other Visitors to our Website from those countries have a right to access Personal Information about themselves, and to amend, correct or delete Personal Information that is inaccurate, incomplete or outdated.  We will, upon request, provide you with confirmation regarding whether we are processing Personal Information about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your Personal Information that is found to be inaccurate, incomplete or processed in a manner non-compliant with this Privacy Policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request.

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.

You authorize us to use and disclose any new or modified information that you provide in accordance with this Privacy Policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

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 will undertake reasonable efforts to investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy.

Any of our personnel that we determine are in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment, where applicable.

USE OF THIRD PARTY COOKIES

We may use third party tracking services to track and analyze information that is collected automatically from use of the Website and Service, such as Internet protocol address, domain names, browser, device type, access times, the web pages you view, and other tracked user actions. Such third parties may use Cookies to help track visitor behavior. We will not use or associate such Cookies with other information of individual visitors to our Website that we Collect.

FEEDBACK

If you provide feedback to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your information.  We will collect any information contained in such feedback and will treat information therein in accordance with this Privacy Policy.

THIRD PARTIES NOT GOVERNED BY THIS PRIVACY POLICY

This Privacy Policy addresses only our use and disclosure of information we collect from or about you. The use and disclosure restrictions contained in this Privacy Policy do not apply to any third party and we do not control the privacy policies of third parties. The Service and Website and content on them may contain links to other sites and resources controlled by third parties. In addition, if you disclose information to others, including to other uses, you are subject to the privacy policies or privacy statements of those third parties where applicable.  We are not responsible for the privacy practices or content of these other sites or resources, and you should consult the privacy policies or privacy statements of such other sites and resources.

DATA SECURITY

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.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy is subject to revision from time to time on a going-forward basis. We will post any revised version of the Privacy Policy on this page. If we make any material changes to it, we may also send you notice thereof to the last email address you have provided to us. Continued use of the Website and/or the Services following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

CONTACT US

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:

http://www.DSPolitical.com
1250 H St. NW, Suite 200
Washington, DC 20005 USA
[email protected]

This Privacy Policy was last revised: May 23, 2018.