Last updated March 2021
1. Personal Data You Provide to Us.
We may collect your personal data when you submit it to us. Data that we may collect includes your:
Your donation history;
Data that you provide in connection with any of our surveys to which you respond; and
Technical data, including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device identifiers, geolocation information, and other technology on the devices you use to access our Site; and
We may collect personal data from various sources, including:
Action Network or Act Blue forms, petitions, signups and donation forms;
White mail processing center; and
Upon receiving your personal data, we create a user profile linked to that personal data. If the same personal data is provided in connection with future donations, actions, or activities on the Sites, such actions will be added to that user profile.
The following list includes the most common ways that you may provide your personal data to us and the types of personal data that we may collect in these ways:
Registration. We do not ask that you register or enter any personal data to access or use most areas of the Sites. However, you may choose to subscribe to certain newsletters or bulletins distributed by Our Power, or to join Our Power’s mailing list. To do so, you may be required to enter certain personal data, including your email address and mailing address. You also have the option to provide us with your telephone number(s).
Online Activism. To send a message from our online action center to government officials and other decision-makers, you are required to identify yourself by name, address, email address, and optional phone number. Our Power includes this information when we send your message. This is necessary for your message to be effective, and in the case of many government officials, it is required. Our Power may also use this personal data to contact you via email, phone or postal mail with the latest alerts and progress reports. Please note that comments sent to governmental agencies may be made available publicly, often via the web, and will sometimes include the full name and address of the person(s) submitting the comments.
Postcards and “Tell Your Friends” Pages. To forward an article, postcard or action alert, you may be required to enter your name, email address and the email address(es) of your intended recipient. Our Power includes your name and email address when we send your message. By submitting personal data about others, you represent and warrant that you have full authority to do so. Our Power only retains and tracks the data of your recipients if they explicitly opt-in.
Donations and Gifts. In order to make a donation through the Site, you will be required to input your name, address, credit card information, and email address for yourself.
When you donate to Our Power, your donation information (i.e., your name, address, donation amount, your credit card number, expiration date of your credit card, and the name and email address of the recipient, if applicable) is encrypted and transmitted via a secure connection. Our Power uses your credit card information only for the purpose of processing your donation. We will not disclose credit card information except as necessary to process your donation or as required by law or legal process, and we do not store credit card information once your donation has been processed.
Communications between you and Our Power. As described in this Policy, you may contact Our Power or subscribe to newsletters and other mailings, and Our Power may respond to your inquiries or request for mailings. Additionally, when you provide Our Power with your email address and mailing address, we may contact you to ask you to become a member of Our Power.
Other purposes. In addition to the above, we may process personal data for other purposes for which either we or our client(s) will provide notice to you at the time of collection.
2. Cookies, Tracking and Analytics.
When you visit our website it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work well. The information does not usually directly identify you, but it can give you a more personalized web experience.
Using the settings of your Internet or mobile browser, you can choose to have your computer warn you each time a cookie is being sent. Because we respect your right to privacy, you can choose not to allow some types of cookies. However, if you choose to disable any cookies, some features of the site may become disabled, and some aspects of the site may not function properly.
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
You can set your browser to block or alert you about these cookies, but some parts of the site may then not work properly. These cookies do not store any personally identifiable information.
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of the site. They help us to know which pages are the most and least popular and see how visitors move around the site.
All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited the site, and will not be able to monitor its performance.
These cookies enable the site to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages.
If you do not allow these cookies then the site may not function properly.
3. Mobile Messaging.
Our Power may also ask for your mobile number so that you can be kept up to date on breaking news and the latest actions via text message.
By subscribing to Our Power alerts, the user consents to receive automated text messages from Our Power. Message and data rates may apply.
There is no fee from Our Power to receive text messages. Message and data rates may apply; you can check this with your mobile service provider. Charges are billed and payable to your mobile service provider or deducted from your prepaid account. Consent is not a requirement for purchase.
Data obtained from you in connection with this SMS service may include your mobile phone number, your carrier’s name and the date, time and content of your messages. We may use this information to contact you and provide the services you request from us. Alerts sent via SMS may not be delivered if the mobile phone is not in range of a transmission site, or if sufficient network capacity is not available at a particular time. Even within a coverage area, factors beyond the control of the wireless operator may interfere with message delivery, including the customer’s equipment, terrain, proximity to buildings, foliage, and weather. Wireless operators do not guarantee message delivery and will not be held liable for delayed or undelivered messages.
We will not be liable for any delays in the receipt of any SMS message as delivery is subject to effective transmission from your network operator.
If you have any questions, email email@example.com.
You can opt out of any type of communication at any time by contacting firstname.lastname@example.org.
You are also able at any time to unsubscribe from specific publications that you are receiving by e-mail by clicking a link that appears in the email publication itself or by visiting the Subscriber Profile Editor link in this Policy.
You can choose not to receive requests to become a member by contacting our membership department at email@example.com.
If you do not want us to collect information about your geographic location, you must disable the technology that transmits this information.
5. Rights of Individuals in the European Union.
This section applies only to individuals in the European Union (the “EU”).
With respect to the personal data we collect directly from you, we are the “data controller,” as defined in the European Union’s General Data Protection Regulation (the “GDPR”).
We will only use your personal data when we have a lawful basis to do so under the GDPR. Usually, we will use your personal data in the following circumstances:
when it is necessary for our legitimate interests, and your interests and fundamental rights do not override those interests;
when we need to comply with a legal or regulatory obligation; or
when we have obtained your consent.
Under the GDPR, individuals in the European Union (“EU Individuals”) have certain rights in relation to their personal data, which are summarized below. These rights are subject to your exercising them in good faith and are subject to our legitimate interests or other valid basis to continue processing your personal data, in accordance with our policies and applicable law.
If asked by an EU Individual and if we are obligated to do so under applicable law, we will inform that individual about whether we are processing his/her personal data. If we are processing such EU Individual’s personal data, we will provide access to the personal data that we have about that individual. If you request additional copies of your personal data, we may charge you a reasonable fee.
Rectification (i.e., Correction)
If the personal data we hold about an EU Individual is inaccurate or incomplete, that individual may ask us to have it corrected.
EU Individuals may request that we erase (i.e., delete or remove) their personal data in certain circumstances. If you are legally entitled to erasure, and if we have shared such personal data with third parties, we will take reasonable steps (taking into account available technology and the cost of implementation) to inform such third parties of your request, to the extent we are required to do so by applicable law.
Restriction of Processing
EU Individuals have the right to restrict the processing of their personal data in certain circumstances, such as if they contest the accuracy of that personal data, if the processing of the personal data is unlawful, or if we no longer need the personal data for our business purposes. If you are legally entitled to restriction, and if we have shared your personal data with others, we will use reasonable efforts to inform such third parties of your request, if we are required to do so.
EU Individuals may ask to receive their personal data from us, where the legal basis of our processing is their consent, and where we carry out the processing of their personal data by automated means. If EU Individuals so request, we may transmit their personal information directly to another organization if it would be technically feasible to do so.
Objection to Processing
EU Individuals may object to the processing of their personal data where we are relying on a legitimate interest (or those of a third party). As noted above, you also have the right to object (i.e., opt out of) our processing of your personal data for direct marketing purposes.
Automated Decision-Making and Profiling
EU Individuals have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us. We do not engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning an individual or similarly significantly affects an individual.
Processing of Special Categories of Personal Data
There are certain types of personal data that require a higher level of protection, known as “special categories” of personal data under the GDPR. We do not process special categories of personal data unless (a) we have obtained such individuals’ explicit consent or (b) we are otherwise legally permitted to do so.
In certain circumstances, EU Individuals have the right to withdraw their consent to our processing of their personal data. However, withdrawal of consent will not affect the lawfulness of any processing that had been carried out before consent is withdrawn. Moreover, if we rely on another legal basis (e.g., legitimate interest) to process your personal data, we may continue to process your personal data in accordance with such other legal basis even after you withdraw your consent. If you decide to withdraw your consent, we may not be able to provide certain services to you.
Please note that where we rely on consent to use your personal data, all users worldwide have the right to withdraw that consent at any time. This includes the option to unsubscribe from our email list at any time or to contact us to request to be excluded from our online campaign promotion lists or text messaging.
EU Individuals who wish to exercise any of the rights they have under the GDPR should contact our data privacy team at firstname.lastname@example.org. We may need to request specific information to help us confirm your identity, so that your personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.
Generally, EU Individuals will not have to pay a fee to exercise the rights described above. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
EU Individuals may lodge a complaint with the appropriate regulatory body or supervisory authority in the country where they reside, where they work, or in the place of the alleged infringement of the law.
6. Sharing of Your Personal Data.
Our Power does not disclose your personal data to any third parties, except (i) to manage the Sites and our database with the help of service providers (who are obligated to maintain its confidentiality), (ii) to send you communications about your interactions with us or about features of the Sites, including any future changes to this Policy, or (iii) as required by law or requested by governmental or law enforcement authorities, subpoena, court order or discovery request, or when we otherwise believe in good faith that such disclosure is appropriate to enforce our Terms of Service or in connection with any activity that may violate the law or the rights of others, threaten the safety or security of any person or property (including the Site) or expose us to liability. In addition, if you visit any website that we jointly maintain with a third party (such as another advocacy organization), that third party will have access to any personal data that you provide on such website.
7. Employment or Volunteer Positions.
In connection with seeking employment or a volunteer position with Our Power, you may decide to submit, through the Sites or otherwise, personal data (including your name, address, telephone number, e-mail address, Social Security number or Tax ID number and any other personal data requested on our online and offline forms, as well as an electronic or paper copy of your resume/CV). All information entered into any online or offline forms related to employment or volunteering will be kept confidential, and will be viewed by Our Power only to assess your qualifications as an employee or volunteer for Our Power.
8. Retention of Personal Data.
We may retain your personal data for as long as is necessary to fulfill the purposes for which we have collected it, including for the purposes of satisfying any legal, regulatory, accounting, reporting, insurance, professional indemnity, internal policy or other requirements.
We may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes. In such cases, we may use this information indefinitely without further notice to you.
9. Other Websites.
This Policy applies only to the site. If you visit any unaffiliated website linked to the site (for example, Twitter, Facebook or other social media sites), you are subject to that entity’s own privacy policies, which we do not control or monitor. You should review the privacy policies of all third-party websites before you visit them. Our Power has not reviewed all of the sites linked to the site and it makes no representations or warranties as to the privacy practices, functioning or content of any sites linked to the site.
10. International Use.
We are based in the United States and our computer servers are located in the United States. Accordingly, all personal data in our possession and control is collected and processed by us in the United States. Any party that provides personal data to us is thereby transferring such data to the United States.
Access to the site from countries or territories where such access is illegal or contrary to applicable rules or regulations is prohibited. Those who access the site from outside the United States do so on their own initiative and are responsible for compliance with local laws, rules and regulations.
11. Children’s Privacy.
The site is not targeted toward, and we do not seek or desire to collect information from, children under the age of 13 in the United States (or age 16 outside the United States). Therefore, we will not knowingly request information from persons under such ages. Please do not provide any personal data to us for any reason unless you are at least the age of 13 in the United States (or age 16 outside the United States), and please caution your children not to do so.
If a child under the age of 13 in the United States (or age 16 outside the United States) has provided personal data to us through the site without verifiable parental consent, a parent or guardian may inform us at email@example.com, and we will use commercially reasonable efforts to delete such information within a reasonable period of time, subject to applicable law and this Policy.
12. California Privacy Rights / “Do Not Track” Signals.
Our Power does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain web browsers allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know that you do not want to be tracked. You should consult your web browser’s “help” feature for instructions on how to set the DNT signal.
Third parties that have content embedded on Our Power’s websites such as a social feature or a stock ticker may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited the Sites from a certain IP address. NDRC does not control or monitor such practices. You should contact such third parties directly to opt out.
13. Security Measures.
We have implemented appropriate technical and organizational measures to ensure a level of security of personal data appropriate to the risk.
15. How You Can Reach Us.