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 (under GDPR) and/or service provider (under 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 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.
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
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 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, 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 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:
Supplemental Privacy Notice for California Residents
Information We Collect
Our Website collects Personal Information. In particular, our Website has collected the following categories of Personal Information from consumers within the last twelve (12) months:
|Category||Examples||Collected on the Website?||Collected by the Service?|
|A. Identifiers||A real name, Internet Protocol address, email address, or other similar identifiers.||YES||YES|
|B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.||NO||NO|
|C: Protected classification characteristics under California or federal law.||Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES||YES|
|G. Geolocation data.||Physical location or movements.||YES||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO||NO|
|K. Inferences drawn from other Personal Information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO||YES|
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 categories of sources:
- Directly from our Customers or their agents. For example, from documents that our clients provide to us related to the Service for which they engage us.
- Indirectly from our Customers or their agents through their use of our Service. For example, data about Audience Members we collect from our Customers through their user of our Service.
- Directly and indirectly from activity on our Website. For example, from submissions through our Website’ portals or website 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, event registrations 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 Website 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 clients 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 both 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:
- Category A – Identifiers
- Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Category F – Internet or other similar network activity.
- Category K – Inferences drawn from other Personal Information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any Personal Information.
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 collected about you.
- The categories of sources for the Personal Information we 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 202-888-7780.
- Visiting http://www.DSPolitical.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 usable 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.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
1250 H St. NW, Suite 200
Washington, DC 20005 USA