Privacy Policy

Effective Date: February 1, 2023

Election Trust Initiative, LLC, a Delaware limited liability company, (“Election Trust Initiative, LLC”, “we”, “us”, “our”) values your private information and understands the need for security and trust surrounding such information. We are committed to protecting your Personal Data, which refers to any data that is used or could be used to identify you (such as your name, email address, street address, or job title).

This privacy policy (“Policy”) is intended to describe what we are doing with your Personal Data, how we protect it, and what privacy rights we offer or you may have under applicable data protection laws.

This Policy addresses data subjects whose Personal Data we may receive when:

You visit our website, electioninitiative.org (or any other website that links to this Policy).
You interact with us on third-party websites or applications, such as social media platforms.
You or third parties share your information as related to our public policy outreach, philanthropic, or fundraising activities.

Please review this entire Policy and feel free to contact us if you have any questions.

Our Role with Respect to Your Personal Data

Within the scope of this Policy, we act as a data controller for the Personal Data we collect and process. This means that we decide how and why Personal Data is collected and further processed.

Lawful Bases for Processing

We must have valid reason(s) to use your Personal Data. This is called the "lawful basis (or bases) for processing".

We may process your Personal Data on the basis of:

Your consent.
The need to perform a contract with you.
Our legitimate interests or those of a third party, such as our interest in marketing activities.
The need to comply with the law.
Any other ground, as required or permitted by law.

Where we receive your Personal Data as part of fulfilling a contract with you, we require such Personal Data to be able to carry out the contract.

To the extent our legitimate interests serve as a lawful basis for processing your Personal Data, those legitimate interests include:

Monitoring for security purposes.
Preventing fraud or abuse.
Monitoring and enhancing the performance of our website.
Responding to your requests for information.
Marketing efforts for our fundraisers and initiatives.
Improving our content and outreach efforts.
Any other ground, as required or permitted by law.

Where we process your Personal Data based on your consent, you may withdraw it at any time. However, this will not affect the lawfulness of the processing we may have completed before you withdrew your consent. The withdrawal of your consent will also not affect the validity of our processing of Personal Data performed on other lawful grounds.

What Personal Data We Collect and How We Obtain It

We may collect the following kinds of Personal Data when you use our website:

Personal Data you provide directly to us

For certain activities, such as when you subscribe to our updates or newsletters, participate in our fundraisers or surveys, or contact us directly, we may collect some or all of the following types of Personal Data:

Contact information, such as your full name, email address, mobile phone number, and mailing address.
Your likeness, image, name, and/or voice recordings, if you provide us with a signed release form.
Any other information you choose to provide to us.

We may combine such information with information we may already have about you.

Information we collect automatically

We and third parties that provide content or functionality on our website may use cookies, pixel tags, Local Shared Objects, and similar technologies to automatically collect certain types of Personal Data. For more information about cookies, pixel tags, Local Shared Objects, and similar technologies, please see our Cookies Notice. For more information about the third parties from whom we collect Personal Data, please see the section below on Information we collect from other sources.

Types of Personal Data we collect automatically include:

Your internet protocol (IP) address.
Device and advertising identifiers.
Browser type.
Operating system.
Internet service provider.
Pages that you visit before and after using our website.
The date(s) and time(s) of your visit(s).
Information about the links you click, the pages you view, the general manner in which you navigate our website, and other standard analytics and server log information.
Location information when you use our website, such as your computer’s IP address.
Technical data to address and fix technical problems and improve our website, including the memory state of your device when a system or app crash occurs while using our website.
- Note: Your device or browser settings may permit you to control the collection of this technical data. This data may include information you were using or editing when a problem occurred, or the contents of your communications.

Information we collect from other sources

We may collect the following categories of Personal Data about you from other sources, including through the third-party services and organizations listed below:

Identifying information (e.g., name).
Contact information (e.g., mailing address, phone number, email address).
Demographic information (e.g., age or age range, geographic location).
Professional information (e.g., professional degree, job title, employer, department).
Device information (e.g., IP address, MAC address, browser fingerprint).
Social network information (e.g., friends, connections, group memberships).
Behavioral information (e.g., browsing behavior, links clicked).
Preference information (e.g., subscriptions, news articles, interests).

We collect the above categories of Personal Data through the following types of third-party services and organizations:

Social media platforms (e.g., Facebook, Google, LinkedIn, Twitter).
Analytics tools (e.g., Google Analytics, Facebook Pixels).
Service providers (e.g., website hosting providers, advertising platforms).
Publicly available sources (e.g., LinkedIn profile, company website).

Our Purposes for Processing Personal Data

We may process your Personal Data for the following purposes:

To provide and improve our website.
To analyze the use of our website and user data to understand and improve the website.
To contact you, including for fundraising purposes.
To send you promotional materials.
To fulfill your requests for information.
To customize the content you see when you use our website.
To prevent potentially prohibited or illegal activities and otherwise in accordance with our Terms and Conditions.
For any other purposes disclosed to you at the time we collect your Personal Data or pursuant to your consent (including using your likeness, image, name, and/or voice on our website, social media channels, multimedia materials, print materials, podcasts, and any other works made by us).

For more information about our use of cookies, please see our Cookie Policy.

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the Personal Data we collect.

Authorized third-party vendors and service providers. We may share your Personal Data with our contracted service providers, who provide us with services, such as IT, system administration and hosting, communication services, payment processing, research and analytics, marketing and advertising, performance monitoring, and support. We take steps to prevent these third parties from using your information for any purpose other than the services they are providing.

Corporate affiliates. We may disclose your Personal Data to our affiliates, The Pew Charitable Trusts and Pew Research Center, which are subject to this Policy.

Fundraiser and event sponsors. If you attend a fundraiser, event, or webinar organized by us, or download or access related content, we may share your Personal Data with sponsors of the fundraiser, event, or webinar. If required by applicable law, you may consent to such sharing when completing a registration form. In these circumstances, your information will be subject to the sponsors’ privacy statements.

Professional advisers. In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.

Business transfers. We may disclose your Personal Data in connection with a substantial corporate transaction, such as the sale of some or all of our company’s business assets, in connection with a corporate restructuring, or in the unlikely event of bankruptcy. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.

Legal purposes. We may disclose your Personal Data to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we must disclose your Personal Data to governmental/law enforcement officials, we may not be able to ensure that such recipients will maintain the privacy or security of your Personal Data.

With your consent or at your direction. We may share Personal Data for any other purposes disclosed to you at the time we collect the Personal Data or pursuant to your consent or direction.

If you access third-party services such as Facebook, Google, LinkedIn, or Twitter from the website or share information about your experience on the website with others, these third-party services may be able to collect information about you, including information about your activity on the website, and they may notify your connections on the third-party services about your use of the website, in accordance with their own privacy policies.

How Long We Keep Your Personal Data

We will retain your Personal Data for as long as is necessary to fulfill the purpose for which we collected your Personal Data and any other permitted linked purpose and in compliance with our data retention policies. For example, we will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

If your Personal Data is used for more than one purpose, we will retain it until the purpose with the longest retention period expires, but we will stop using it for the purpose with a shorter retention period once that period expires. Our retention periods are also based on our organization’s needs and good practice.

Security

We use reasonable measures to help protect your Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Examples of reasonable measures we use include restricting access to our website and system based on roles; encrypting Personal Data at rest and in transit; and other commercially appropriate policies, procedures, and technologies for Personal Data we store or process. We make all required and reasonable efforts to ensure that all our third-party service providers protect your Personal Data that we may have shared with them.

Your Rights and Choices

You may have specific rights regarding your Personal Data that we collect and process. In this section, we first describe those rights and then we explain how you can exercise those rights.

Under certain circumstances, we may deny your request to exercise the below rights, including if the right is not granted to you under applicable data protection laws. If we deny your request to exercise these rights, we will inform you of our reason.

The right to know what happens to your Personal Data. You may have the right to be informed, meaning we will provide you with information regarding our data processing activities that concern you, such as how we collect and use your Personal Data, how long we will keep it, and who it will be shared with, among other things. We are informing you of how we process your Personal Data with this Policy.

We will always try to inform you about how we process your Personal Data. However, if we do not collect the Personal Data directly from you, we may not be able to inform you (i) when providing the information is either impossible or unreasonably expensive; (ii) the gathering and/or transmission is required by law, or if (iii) the Personal Data must remain confidential due to professional secrecy or other statutory secrecy obligations.

The right to know what Personal Data we have about you. You may have the right of access, meaning you may ask for full details of the Personal Data we hold about you, including confirmation of whether or not we process Personal Data concerning you, and where that is the case, a copy of your Personal Data and certain related information.

Once we receive and confirm that the request came from you or your authorized agent, we will disclose to you:

The categories of your Personal Data that we process.
The categories of sources for your Personal Data.
Our purposes for processing your Personal Data.
Where possible, the retention period for your Personal Data, or, if not possible, the criteria used to determine the retention period.
The categories of third parties with whom we share your Personal Data.
If we carry out automated decision-making, including profiling. meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
The specific pieces of Personal Data we process about you in an easily-sharable format;
If we disclosed your Personal Data for a business purpose, the categories of Personal Data and categories of recipients of that Personal Data for and disclosure.
If we rely on legitimate interests as a lawful basis to process your Personal Data, the specific legitimate interests.

Under some circumstances, we may deny your access request. In that event, we will respond to you with the reason for the denial.

The right to change your Personal Data. You may have the right to rectification, meaning you may ask us to correct (without undue delay) anything that you think is wrong with the Personal Data we have on file about you, and to complete any incomplete Personal Data.

The right to delete your Personal Data. You may have the right to erasure, also known as the right to deletion or the right to be forgotten. This means you can ask for your Personal Data to be deleted.

Sometimes we can delete your information, but other times it is not possible for either technical or legal reasons. If that is the case, we will consider if we can limit how we use it. We will also inform you of our reason for denying your deletion request.

The right to ask us to limit how we process your Personal Data. You may have the right to restrict processing, meaning you may ask us to only use or store your Personal Data for certain purposes. You have this right in certain instances, such as where you believe the data is inaccurate or the processing activity is unlawful.

The right to ask us to stop using your Personal Data. You may have the right to object, meaning you can tell us to stop using your Personal Data. You may have this right where we rely on a legitimate interest of ours (or of a third party).

We will stop processing the relevant Personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim; or (iii) this is not a right granted to you under applicable data protection laws.

You may also object at any time to the processing of your Personal Data for direct marketing purposes. You may opt out of our email newsletters by clicking the “unsubscribe” at the bottom of each newsletter and following the subsequent instructions. You may also opt out of all communications from Election Trust Initiative, LLC by contacting us. Once you “opt out”, you will no longer receive any marketing emails from us. We will continue to communicate with you regarding payments and support via email.

The right to port or move your Personal Data. You may have the right to data portability, meaning you may ask for and receive a portable copy of your Personal Data that you have given us or that you have generated by interacting with us, so that you can (1) move it; (2) copy it; (3) keep it for yourself; or (4) transfer it to another organization.

We will provide your Personal Data in a structured, commonly used, and machine-readable format. When you request this information electronically, we will provide you a copy in electronic format.

The right to withdraw your consent. Where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. If you withdraw your consent, our use of your Personal Data before your withdrawal is still lawful.

If you have given consent for your details to be shared with a third party and wish to withdraw this consent, please also contact the relevant third party in order to change your preferences.

Where you have provided us with your consent to use your likeness, image, name and/or voice on Election Trust Initiative, LLC’s website, social media channels, multimedia materials, print materials, podcasts, and any other works made by Election Trust Initiative, LLC you can withdraw your consent, although it may not be possible to ensure the complete removal of your information from third-party websites.

Exercising Your Privacy Rights

To exercise any of the rights described above, please contact us.

Identity verification. Before processing your request, we may verify your identity by having you provide information we already know that is not publicly available or likely to be known by an unauthorized individual, such as your email address, phone number, or mailing address. We may also verify your identity by sending a one-time use access code to the email address or phone number we have for you. If necessary, we may request additional information from you in order to verify your identity. We will only use the Personal Data you provide us in a request to verify your identity or authority to make the request.

If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual, or proof of parental responsibility or legal guardianship. Alternatively, you may ask the individual to directly contact us to verify their identity and confirm with us that they gave you permission to submit this request.

Response time and format. We will confirm the receipt of your request within ten (10) business days and, in that communication, we will also describe our identity verification process (if needed) and when you should expect a response, unless we have already granted or denied the request.

Please allow us up to thirty (30) days to reply to your request. If we need more time (up to 90 days in total), we will inform you of the reason why and the extension period in writing.

If we cannot satisfy a request, we will explain why in our response. For data portability requests, we will choose a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without difficulty.

We will not charge a fee for processing or responding to your requests. However, we may charge a fee if we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination and provide you with a cost estimate before completing your request.

United States Only

Our site and communications are only intentionally directed to individuals within the United States. By visiting our website and interacting with our communications, you understand that your Personal Data may be transferred to and stored on servers located in the United States and is only protected to the extent as required by the laws of the United States and our internal security practices.

Children

We do not knowingly collect any Personal Data from children who are under the age of 13 without parental consent. If we learn that a child under the age of 13 has provided us with Personal Data, we will delete it in accordance with applicable law.

Changes to this Privacy Policy

We may update this Policy from time to time. When we update this Policy, we will revise the “Effective Date” above and post the new Privacy Policy. We recommend that you review the Privacy Policy each time you visit our website to stay informed of our privacy practices.

Contact information

If you have any questions about this Policy or our practices, please contact us.