Effective Date: May 13, 2024

Campaign Name: Leonard Spencer for State House

Campaign Support e-mail: [email protected]

This Privacy Policy explains how the above-named campaign (the “Campaign,” “we,” or “us”) collects, uses, and discloses information about you when you access or use our websites and mobile sites that link to this Privacy Policy (collectively, the “Site”).

Collection of Information

INFORMATION YOU PROVIDE TO US

We collect information you provide directly to us. For example, we collect information when you sign up to receive updates, request information, fill out a form, sign a petition, sign up as a volunteer, sign up for an event, participate in a contest or promotion, make a donation or purchase, communicate with us via third party social media sites, request support, send us an email, or otherwise communicate with us. The types of information we may collect include your name, contact information (such as email address, postal address, and phone number), credit card and other payment information (although payment information may be collected directly by a third-party processor), and any other information you choose to provide.

In addition, the applicable election regulatory body may require us to collect certain personal information from donors.

AUTOMATICALLY COLLECTED INFORMATION​

When you access or use our Site, we automatically collect information about you, including:

Log and Usage Information

We collect information related to your access to and use of the Site, including the type of browser you use, app version, access times, pages viewed, your IP address, and the webpages you visited before and after navigating to our Site.

Device Information

We collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

Transactional Information

If you make a donation or purchase, we may collect information about the transaction, such as donation amount, purchase price, product details, and date and location of the transaction.

Location Information

We may derive the approximate location of your device, such as from your IP address.

Information Collected by Cookies and Other Tracking Technologies

We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Site or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Your Choices below. For more information about the use of cookies and similar technology on our online services please review this Privacy Policy and the Advertising and Analytics and Cookies sections below.

INFORMATION WE COLLECT FROM OTHER SOURCES

We and our service providers may also obtain information about you from other sources and combine that with information we collect about you on our Site. For example, we may collect voter file data from state parties and other affiliated organizations, from public databases, and from private organizations.

Campaign Purposes and Uses of Information

We may use the information we collect to:

• Provide, maintain, and improve our Site;
• Provide and deliver the information you request, process donations and transactions and send you related information, including confirmations and receipts,
• Send you technical notices, updates, security alerts, and support and administrative messages and provide technical support;
• Respond to your emails, submissions, comments, questions and requests; request feedback or support, and otherwise contact you about your participation in the campaign and use of the Site;
• Communicate with you about the campaign, such as sending you information to keep you informed about various issues, events, activities, and volunteer opportunities, and provide news and information we think will be of interest to you (see Your • Choices below for information about how to opt out of these communications at any time);
• To solicit volunteers, donations and support for the Campaign and for other candidates, campaigns, issues and organizations that we support and to connect you with other volunteers;
• Contact you if applicable election laws require us to request additional information from you;
• Remind you to vote and register to vote and assist you in finding your registration information, polling location and campaign events near you;
• Monitor and analyze trends, usage, and activities in connection with our Site;
• Personalize the Site and provide advertisements, content or features based on your preferences, interests, and browsing and online activities;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of the Campaign and others;
• Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, service providers, volunteers, and consultants who need access to such information to carry out work on our behalf;
• With candidates, campaigns, political or nonprofit organizations, groups or causes that we believe have similar political viewpoints, principles or objectives or share similar goals and with organizations that facilitate communications and information sharing among such groups or otherwise assist such groups;
• With other participants in a joint fundraising committee;
• To report required information to the applicable elections regulatory body;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims or legal authorities, including responding to lawful subpoenas, warrants, or court orders;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of the Campaign, its employees, volunteers, constituents, or others;
• In connection with, or during negotiations of, any reorganization, formation of new committee or successor organization, asset sale or transfer, financing or lending transaction or in any other situation where personal information may be disclosed or transferred as one of the assets of the Campaign;
• With your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used by third parties to identify you.

Data Retention

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate campaign purposes, including to meet our legal, regulatory or other compliance obligations.

Links to Other Websites

The Site may contain links to other websites. For example, we may link to third-party sites to facilitate donations or purchases. Any personal information you provide on such linked pages is provided directly to that third party and is subject to that third party’s privacy policy, and not this privacy policy. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.

Social Sharing Features

The Site may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Site with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on your privacy settings for the relevant social media site. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Site and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by the Campaign and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Site and other websites, and better understand your online activity.

For example, we may use Google Analytics and Remarketing with Google Analytics or other remarketing tools to advertise online. Using these tools enables third-party vendors, including Google, to show our ads on sites across the Internet. Such third-party vendors may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our Site.

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. You can also change your browser settings to block cookies, although doing so may disable some features of our Site.

Transfer of Information to the U.S.

The Campaign is based in the United States and is directed to United States residents. We process and store information in the United States. While we do not direct our services to residents of other countries, it is possible that those residents may access and use the Site. If you are located outside the United States, we and our service providers may transfer your information to, or store or access to your information in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. By providing personal information, you consent to the transfer of your personal information to the United States and the use of your personal information, in accordance with this Privacy Policy. If we collect personal information from European Union residents, we strive to do so in a manner in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (the “GDPR”), which includes acknowledgment of European Union residents’ rights, including the following:

• to withdraw your consent to the processing of personal information about you to which you have previously given consent;
• to object to processing of personal information about you for the purpose of direct marketing; and
• to have incorrect personal information about you corrected.

European Union residents also have the right to obtain a copy of the personal information we have about you, although we reserve the right to charge a fee for this.

Your Choices

PROMOTIONAL COMMUNICATION

You may opt out of receiving promotional emails or text messages from the Campaign by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional emails, such as those about your use of the Site.

UPDATING INFORMATION

You may update and correct certain information you provide to us by emailing us at Campaign Support. If you wish to delete information we have collected from you, please email us at Campaign Support, but note that we may retain certain information as required by law or for legitimate campaign purposes. We may also retain cached or archived copies of information about you for as long as necessary for our business purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. For more information about cookies and how to disable them, you can consult the information at www.allaboutcookies.org/manage-cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Site. You may also opt out of third-party advertising networks by going to http://optout.networkadvertising.org. We are not responsible for the effectiveness of any such opt-out options. California residents may be entitled to know the effects of opt-out options under California Business & Professions Code Section 22575(b)(7). The effect of an opt-out, if successful, will be to stop targeted advertising, but it will still allow the collection of usage data for certain purposes (e.g., research, analytics and internal site operation purposes).

The Site uses cookies and tracking technologies. We use these cookies for a variety of purposes, including to remember your log-in status and viewing preferences from your previous use of our online services for when you later return to that online service. Our Site and online services use the following categories of cookies:

• Strictly Necessary Cookies: We may use cookies required for system administration and to prevent fraudulent activity. We are not required to obtain your consent to use cookies that are strictly necessary.
• Analytics and Performance-Related Cookies: We may use cookies to assess the performance of our online services, including to improve the content offered through the online services.
• Functionality-Related Cookies: We may use cookies to tell us, for example, whether you have visited the online services before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.
• Targeting-Related Cookies: We may use cookies to deliver content, including advertisements relevant to your interests, on our online service and third-party sites based on how you interact with our advertisements or content.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Your California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at Campaign Support.

HOW WE RESPOND TO DO NOT TRACK SIGNALS FOR CALIFORNIA RESIDENTS

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how the Campaign responds to “Do Not Track” browser settings. The Campaign does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

CATEGORIES OF PERSONAL INFORMATION SOLD AND DISCLOSED FOR A BUSINESS PURPOSE

Pursuant to the California Shine the Light Law (Cal. Civil Code Section 1798.83), California residents have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.

Although, as a non-profit with fewer than 20 employees, the Campaign is not subject to the California Shine the Light Law, any future disclosures to services providers will strive to be consistent, however, with the spirit of the Shine the Light Law. In the future, we may share your personal information with service providers as necessary to perform a campaign business purpose, including fundraising, publicity, sponsorships, e-commerce or other campaign related activities, and in a manner consistent with applicable law.

Further, as a non-profit, we are not a “business” subject to the California Consumer Privacy Act (“CCPA”) that goes into effect on January 1, 2020. Any disclosures to services providers will strive to be consistent, however, with the spirit of the CCPA (Cal. Civ. Code Section 1798.135 as of its effective date on January 1, 2020).

Children

The Sites are not directed at children and we do not knowingly collect personal information directly from children (including information concerning a child or that child’s parents or guardians, any screen or user name that functions as online contact information for a child, any photograph, video, or audio file containing a child’s image or voice) directly from users under the age of thirteen (13) or from other web sites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act of 1988 (“COPPA”), we will not knowingly request or collect personal information from any child under the age of thirteen (13) in the United States without obtaining the required consent from the appropriate parent or guardian. Children may access and browse the Site without disclosing any personal information. We will apply material changes to this Privacy Policy to conform with applicable law, including any applicable provisions of COPPA that require parental consent. Please visit www.ftc.gov/privacy/privacyinitiatives/childrens.html for information from the Federal Trade Commission about protecting children’s privacy online. If you have any reservations, questions or concerns about your child’s access to the Site or how information that your child provides is used by us, please contact us.