Definition of Personal Information
We collect certain “personal information” from visitors to our site and otherwise. The CCPA defines personal information as information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The CPA, CTDPA, UCPA, and VCDPA define personal information or personal data as any information that is linked or reasonably linkable to an identified or identifiable individual. Personal information does not include:
- Publicly available information from government records;
- Aggregated or Anonymized/De-identified information; or
- Information excluded from the scope of the Applicable Laws, like:
- 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 other privacy laws.
What Personal Information We Collect
We may have collected the following categories of personal information from consumers within the last twelve (12) months:
|Identifiers||Real name, alias, postal address, personal and work phone number, unique personal identifier, online identifier, Internet Protocol address, personal photograph/image, personal and work email address, account name, and other similar identifiers|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Name, signature, 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, or health insurance information. Some personal information included in this category may overlap with other categories|
|Protected classification characteristics under California or federal law||Age (40 years or older), physical or mental disability, veteran or military status|
|Internet or similar network activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, broad geolocation (not precise)|
|Sensitive Personal Information, with your consent where required||Your Social Security number, driver’s license number, passport number, state identification card, racial or ethnic origin, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation or EEOC monitoring information (ethnicity, religion, gender and sexual orientation)|
Categories of Sources
We obtain the categories of personal information listed above:
- from activity on our websites or mobile application (for example, from submissions to our mobile application or through our website portals, or from automatically collected website or mobile application usage details);
- from donors and other individuals that sign up for our newsletter or otherwise; and
- from third parties from whom we obtain products or services.
How We Use Personal Information
We may use or disclose personal information we collect for one or more of the following business purposes:
- To fulfill a request or satisfy the reason for which the information is provided. For example, if an individual provides a donation, they may also provide their name, credit card information, email address, and/or other information so that we can provide them confirmation of and a receipt for their donation;
- To comply with reporting and other campaign finance requirements under the law;
- To provide our contacts with email alerts, event registrations and other notices concerning our campaign, events, news, or other items that may be of interest;
- With regard to website visitor information, to measure the number of visitors to different pages on the website, conduct statistical modeling and evaluate, modify and enhance our websites, our services and our business. We also use this information to monitor network traffic and to identify unauthorized access or unusual activity on the website;
- As required by applicable laws, regulations, and court orders;
- To respond to law enforcement requests; and
- As otherwise described to you when collecting your personal information.
Disclosure of Personal Information
With regard to your personal information:
- We do not sell or share personal information to third parties for advertising or marketing products and services to you, or to third parties whose purpose in acquiring the information is to sell your personal information to others for advertising or marketing purposes.
- We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without first providing you notice in the manner specified in the “Changes to this Notice” section of this Notice.
- We may disclose your personal information to third parties for campaign-related purposes. Before we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient not to use or disclose the information except for purposes specified in the contract (typically to perform services for us).
- We are required to disclose information regarding our contributions to comply with campaign finance laws. Federal law requires us to use our best efforts to collect and report the name, mailing address, occupation and name of employer of individuals whose contributions aggregate in excess of $200 in a calendar year.
- We release personal information when we believe release is necessary or appropriate to comply with the law (e.g., a lawful subpoena); to protect our rights or property; to protect our donors and supporters from fraudulent, abusive, or unlawful conduct; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires the disclosure of communications or records.
We disclose your personal information to the following categories of third parties:
- Service providers;
- Third parties who assist us with this or our other websites, or our applications. This may include information you provide as part of voluntary surveys about application or website-related issues taken while or after visiting the site;
- We may disclose selected personal information to other candidates, campaigns and organizations that we believe are like-minded or that we believe you may wish to hear from.
- We also may disclose personal information to regulators or other law enforcement entities or as otherwise required by applicable laws, regulations, and court orders.
In the twelve (12) months preceding the date of this Notice, we have not sold or shared any personal information other than as specified in this Notice.
We may retain your personal information for the longer of five (5) years or the period permitted by applicable law. In any case, we will retain your information for no longer than we believe is reasonably necessary to fulfill the purposes for which it was collected.
Your Rights and Choices under the CCPA, VCDPA, CTDPA, and UCPA
California, Virginia, Connecticut, and Utah provide their respective residents with specific rights regarding their personal information. As noted previously, we are not subject to the privacy laws of these states, and with that in mind, while we can’t guarantee we will be able to fulfill your requests regarding your information, we will take reasonable steps to do so where we believe it is appropriate.
Your Colorado Privacy Rights (starting July 1, 2023)
Starting July 1, 2023, we may be subject to the CPA, which provides residents of Colorado with specific rights regarding their personal information. Should we be subject to the law, this section describes the rights of consumers who are residents of Colorado 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. Before we disclose information to you, we will ask you for information to verify your identity. Once we receive and confirm your verifiable consumer request, we will disclose to you whether we process your personal information and provide you with access to your personal information. We will provide a copy of personal information we have obtained about you in a portable and, to the extent technically feasible, readily usable format.
Please note that we may not disclose the information you have requested if we are unable to verify your identity. In addition, we may not disclose certain information that is covered by one or more exemptions, as outlined in the CPA.
Deletion Request Rights
You have the right to request that we delete personal information that we collected and retained. 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. Note that other state and federal laws may prevent us from being able to delete your information. If we deny your deletion request, we will inform you and explain the basis for our denial.
Correction Request Rights
You have the right to request that we correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing. Once we receive and confirm your verifiable request, we will correct your personal information from our records, unless an exception applies. If we deny your correction request, we will inform you and explain the basis for our denial.
If we deny your request, you have the right to appeal our decision. We will respond to appeals within 45 days.
How to Exercise Your Colorado Privacy Rights
To exercise any of the rights described above, please submit a request to us by either:
- Emailing us at [email protected]; or
- Writing us at: PO Box 33079 Washington, DC 20033
You must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.
As noted, we respond only to requests that are verifiable consumer requests. Therefore, when you submit a request to us, we will seek to verify your identity by asking you to provide us with information that enables us to identify you, such as your email address or the last four digits of your social security number. We also may use a third-party verification provider to verify your identity.
We will not 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.
Changes to This Notice
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will notify you by posting the updated Notice on our website homepage. Please be sure to check back periodically for any updates.
1 For example, under California’s privacy law, the CCPA, nonprofits do not qualify as a “business” as that law defines the term, and thus are not subject to its requirements. At this time, only Colorado’s CPA applies to nonprofits.