Last updated: May 23, 2018
1. PRIVACY PRINCIPALS
We follow the following principles in order to protect your privacy:
- We do not collect any more personal information about you than is necessary;
- We do not keep your personal information if it is no longer needed; and
Personal data is collected from you in a variety of different ways, at different times, including when you sign up to use the Platform, register for an account, contact us or when you take part in a survey or prize draw.
The Platform is not intended for children and we do not knowingly collect information about children.
For purposes of the General Data Protection Regulation (the “GDPR”), the controller of any personal data collected by Campaign is Denise Kelly. Campaign is located in Lower Fitzwilliam Street, Dublin 2, Ireland and its lead supervisory authority for purposes of the GDPR is Data Protection Commissioner of Ireland
3. COLLECTION AND USE OF PERSONAL DATA
INFORMATION YOU PROVIDE
We will collect personal data when you register an account with us, use the Platform or its features to communicate with us, interact with others via the Platform, contact us, or register to receive updates from us. As part of the registration process, we may collect login information such as your username, password, and security questions and answers. After registering an account, you may also choose to provide certain profile information, including your age, gender, profile image, and political affiliation.
Although you need to register for an account to use the Services, you can still browse the Platform as a visitor without entering any personal data. Although the Platform logs IP addresses and browser types, we do not link this information to anything which could identify you as the user. Your session on the Platform will be tracked, but you will not be identifiable through that information.
When using the Platform, you may send messages to other users of the Platform or to external recipients. We receive copies of the messages you send to, and receive from, these individuals. We also receive personal data when you choose to connect social media or other third party accounts and applications with your account via the Platform.
The Platform also logs IP addresses and browser types for systems administration purposes and these logs will be analyzed to improve the performance and display of the Platform.
Finally, we may also collect geolocation information as provided by your phone or other mobile device to the extent that you allow this option on your mobile device. If you access our Platform through a mobile device, you may adjust the settings on your mobile device to allow or prevent the sharing of location information. For example, you can disable “Location” (or “Location Services” on iOS-based devices) on your mobile device to prevent sharing your location information with Political Social Media, or only disable “Bluetooth” to prevent the sharing of information collected via nearby Bluetooth proximity beacons. Please note that if you disable the sharing of location information, you may be unable to access some features of our Platform that are designed for mobile devices.
INFORMATION OTHERS SHARE ABOUT YOU
We may receive personal data about you from other users of the Platform, if they invite you to use our Services via the Platform. If we receive personal data about you from a third party we will contact you to let you know who provided it to us, and other information as required by GDPR. You have the right to withdraw your consent to our processing of your personal data provided by a third party at any time.
INFORMATION YOU DISCLOSE THROUGH USE OF THE PLATFORM
4. PURPOSES AND LEGAL BASIS FOR PROCESSING
We use your contact information as necessary to respond to your inquires and as necessary to provide you with access to the Platform and provide the Services you have requested.
With your consent, we may use your personal data for marketing purposes, including providing you with personalized advertising content. We will provide you with an opportunity to unsubscribe from receiving such marketing communications as part of every communication we send to you. If you would like to stop receiving marketing messages from us, you can contact us using the information below, unsubscribe using the link in any email you receive from us, or update your preferences via the Platform.
If you use the Platform to send a friend an invitation to join the Platform, the information you provide will only be used to facilitate the communication on your behalf and will not be used for other purposes unless we obtain consent from that person.
5. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
We may share non-personal data, such as aggregate user statistics, demographic information, and usage information with third parties.
CAMPAIGNS YOU SUPPORT AND ALIGNED ORGANIZATIONS
With your consent, we may share your personal data with other organizations, groups, causes, campaigns, political organizations, and our clients that we believe have similar viewpoints, principles or objectives as us.
We may share your personal data with other users of the Platform, if they invite you to use our services via the Platform.
THIRD PARTIES PROVIDING SERVICES ON OUR BEHALF
We may share your Personal Data with other entities affiliated with us for our internal business and operational purposes. In addition, your personal data may be transferred to a third party acquirer in the event Campaign, or any of its assets, including the Platform, is sold.
COMPETITIONS AND OTHER PROMOTIONS
If you choose to register for a promotion, such as a competition, prize draw or contest, your personal data may be disclosed to third parties for purposes of the administration of such promotion.
LEGAL PROTECTIONS AND LAW ENFORCEMENT
6. Information we collect automatically
In addition to the personal data you may provide to us as described above, we automatically collect certain device and statistical information to make our Services and Platform work better for you. This information helps us evaluate how users and members use our Services, such as data analysis, carrying out internal research on how our website is used, audits, developing new products and services, improving our services, identifying usage trends and determining the effectiveness of promotional campaigns.
The technologies we use to gather this non-personal information include:
IP Addresses: IP addresses define the Internet location of computers and help us better understand the geographic distribution of our members and manage the performance of our website. We use your IP address to help diagnose problems with our server, and to administer the Platform.
Web logs: To learn about how people use our Platform, we examine Web logs, which show the paths people take through our site and how long they spend in certain areas. We also use Web logs to detect the type of Web browser you are using so that we can optimize the performance of the Platform and understand the mix of browsers used by our users.
Cookies: Cookies are tiny files that are placed onto the hard drive of your computer when you visit our website. They let us immediately recognize you when you return to the site. This enables us, among other things, to personalize your experience with our site. We use Google Analytics and Google Adwords web analytics and marketing tools to help us directly market to and understand how visitors engage with the Platform. You may choose to opt out of Google Analytics and still have full access to the Sites. You can learn more about cookies by visiting www.aboutcookies.com, and you can modify your cookie setting by following the instructions provided by your browser. These instructions are usually found in the “Tools,” “Help” or “Edit” tabs. If you set your browser to disable cookies you may not be able to fully access and use our Sites. You can learn more about the choices provided by advertisers for individuals to decide how their information is collected and used by visiting the European Digital Advertising Alliance (www.youronlinechoices.eu).
7. YOUR RIGHTS REGARDING YOUR PERSONAL DATA
EU privacy law, including the GDPR, gives you a number of rights with respect to your personal data, including:
RIGHT TO ACCESS: You have the right to request a copy of any personal data that we hold about you. If you would like a copy of this information please contact us by writing to us at 60, Clifton House, Lower Fitzwilliam Street, Dublin 2 or email us at email@example.com . We may request proof of your identity before sharing such personal data with you.
RIGHT TO RECTIFY YOUR PERSONAL INFORMATION: If you discover that the personal data we hold about you is incorrect or out of date, you may ask us to correct that information.
RIGHT TO BE FORGOTTEN: You may ask us to delete the personal data we hold about you in certain circumstances. It may not be possible for us to delete all of the personal data we hold about you where we have a legal obligation to retain it, however please contact us and we will do our best to assist with your request.
CONSENT: Where we process your personal data on the basis that you have consented to such processing, you have the right to withdraw your consent at any time by contacting us. Additionally, certain of our communications may include options to opt-out or unsubscribe.
OTHER RIGHTS: In addition to the foregoing, you may also ask us to stop or restrict processing of the personal data we have about you. You may also ask us to transfer your personal data to a third party in certain circumstances. If you would like any other information on these aspects of your rights, please contact us.
We maintain commercially reasonable technical, organizational and administrative safeguards to help protect and secure your personal data. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure.
9. WHERE WE STORE YOUR PERSONAL DATA
The personal data we collect from you may be transferred to, and processed and stored by, third parties acting on our behalf, at a destination outside of the European Economic Area (“EEA”). In order to ensure that any third party processes your personal information in a way which is consistent with the EU’s laws on data protection, to the extent that we share data outside of the EEA, we will seek to put in place agreements with those third parties which contain provisions approved by the EU for providing adequate protection for your personal data.
10. HOW LONG WE RETAIN YOUR PERSONAL DATA
We will retain your personal information for as long as is necessary for the purposes for which it was collected. Certain laws may require us to hold certain information for specific periods. In other cases, we may retain data for an appropriate period after any relationship with you ends in order to address legal claims or administer our business.
12. GOVERNING LAW
13. Information Concerning Data Privacy
If you have provided your verbal consent to one of our canvassers, volunteers or staff to collect personal information, this information may be used for the purposes of delivering content specifically related to the Love Both Project via email, phone, and digital marketing. It is possible that, at your request, we may have gathered this information for the expressed purpose of avoiding future communications. This information will be stored in a secure, cloud based system and will not be sold to a third party vendor. If you have concerns, or would like to be removed from our database in the future, please submit an email request to our data controller at: firstname.lastname@example.org
14. CONTACT INFORMATION
You also have the right to lodge a complaint directly with a supervisory authority. You can complain to the Data Protection Commissioner of Irealnd by writing to 21 Fitzwilliam Squre, Dublin 2
If you would prefer to make a complaint to a different supervisory authority, we would be happy to provide you with further information on how you can do this.