Privacy Policy

Effective Date: June 18, 2019

Last Updated: June 30, 2023

SCOPE

This Privacy Policy (“Policy”) describes how WinRed Technical Services, LLC (“TS,” “we,” or “us”) treats information that identifies, or can be used to identify, you as an individual (“personal information”) on our websites and platforms where the Policy is located (the “Platform”).

This Platform facilitates your ability to make contributions to various political committees and campaigns. The pages on our Platform may be created by individuals or groups (“page creators”), political committees or campaigns. By using this Platform, you acknowledge and agree that when you use this Platform, TS does not control how these page creators, political committees and campaigns collect, use or disclose your information, including through cookies or other tracking technologies on their pages. For more information on a specific page creator’s, political committee’s or campaign’s privacy practices, please review that entity’s privacy policy.

This Platform is intended for use by individuals who are eighteen (18) years of age or older and are located in the United States.

NOTICE AT COLLECTION

We collect personal information from you and about you. Here are some examples of the information we may collect; how we may collect, use and disclose it; and whether we share it for cross-contextual advertising purposes (“sharing”) or sell it. Below this Notice At Collection, you will find more detailed descriptions of how we may collect, use and disclose personal information, including more information about the business partners to which we may share or sell personal information.

Contact Information. This may include your name, address of residence, billing address, email address or telephone number.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to provide political communications; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; on our Platform; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with campaign finance laws; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Political Information. For example, we may collect information about your political party affiliation and opinions and candidates or political issues that interest you.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; on our Platform; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with campaign finance laws; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Voter Registration Information. We may collect information about the jurisdiction where you are registered to vote, whether you are currently registered to vote, and what polling locations you use. We may also collect information about when you last voted, whether you participated in early voting and whether you submit votes through absentee ballots.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; on our Platform; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Contribution Information. For example, we may collect information about the amount of contributions you make and the candidates you support. We may publicly post on our Platform your first name, your city and state, the amount of your donation and the candidate you support.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; on our Platform; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with campaign finance laws; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Payment information. For example, we may collect your payment card number, type and expiration date.

How We May Collect It: Directly from you and passively.
How We May Use It: To provide our Platform and services; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; with our service providers; with any successors to all or part of our business; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.
We do not share this information for cross-contextual marketing purposes or sell this information.

Demographic information. This may include your age or date of birth, sex or gender, or your ZIP Code.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with campaign finance laws ; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Information That You Post or Submit. We may collect information when you send us a message through the “Contact Us” page or similar features on our Platform. We may also collect information when you enter a promotion. This may include photos, videos and other user-generated content that you submit. This may include various petitions, forms, and surveys. We may also collect information you post in a public space on our Platform, such as when you post a design or logo for a candidate in connection with a promotion.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; on our Platform; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.
We do not share this information for cross-contextual marketing purposes or sell this information.

Social Media Information. We may collect information you post on candidate, political committee, or campaign social media pages. We may also collect your social media profile information and information posted on your page. You may also choose to link your social media account with an account you create on our Platform.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to provide political communications; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; on our Platform; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Internet or other similar network activity. This may include unique online personal identifier, online or mobile device identifier, IP address, device identifier, browsing history, search history, language, and information regarding interaction with an Internet website, application, or advertisement. This may also include location-based information derived from your IP address or other technical information about the state or country from which your accessed our Platform or information about the browser or operating system you are using or what site you came from and what site you visit when you leave us. It may also include the specific pages you visited or items viewed on our Platform, the date and time of your visit, the number of links and specific links you click within our Platform and the functions used on our Platform.

How We May Collect It: Passively or from third parties.
How We May Use It: To provide our Platform and services; to provide political communications; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Employment information. For example, we may collect information about your employment status, employer and occupation. We may also ask whether you are retired.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with campaign finance laws; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Inferences drawn from other Personal Information. This may include a profile relating to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitude.

How We May Collect It: Directly from you; passively; or from third parties.
How We May Use It: To improve voter modeling or scoring; to provide our Platform and services; to improve our products and services; to understand your interests; for marketing purposes; for security purposes; to combine information; as otherwise permitted by you or as we may notify you; or as directed by you.
How We May Disclose It: Internally; with page creators, political committees and campaigns; with our business partners; with our service providers; with third parties for marketing purposes; with any successors to all or part of our business; to comply with other laws or to protect ourselves; for other reasons we may describe to you; or as directed by you.

We may share this information for cross-contextual marketing purposes with, or sell this information to, our business partners. For more information about your right to opt out, please click here.

Our Personal Information Retention Criteria: The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) requires that we disclose the criteria we use to determine how long we will retain each category of personal information we collect. Oftentimes, our records contain several of these categories of personal information combined together and therefore we consider, on a case-by-case basis, a number of factors to assess how long personal information is retained, including any periods of time that are permitted or required by law. These factors include what personal information is reasonably necessary to (i) fulfill the purposes for which the personal information was collected; (ii) provide our products and services or administer our relationship with an individual; (iii) protect our business, employees, organization and others; (iv) fulfill our legal, contractual and regulatory obligations; and (v) investigate and address issues that may include safety concerns, potential security incidents or policy violations.

HOW WE COLLECT YOUR INFORMATION

We collect your information in different ways. Below, you will find additional details and examples regarding how we may collect your personal information.

Directly From You. For example, when you:
- Register for an account.
- Make a contribution.
- Make a purchase through an online store on our Platform (all purchases made through an online store are considered to be contributions).
- Sign up to receive promotional communications.
- Sign up for a candidate’s, political committee’s or campaign’s newsletter.
- Participate in one of our promotional sweepstakes, contests, surveys, or focus groups.
- Submit a design or logo for a candidate or campaign.
- Submit a review or vote on candidate or campaign design or logo.
- Submit a request to our customer service team.
- Interact with TS, candidate, campaign or political committee social media pages.

Our service providers may collect information from you on our behalf.

Passively.For example, we may passively collect or record information when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform. We may collect information when you interact with an electronic communication. Third parties may also collect personal information this way on our Platform.
From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from:
- Our business partners. This may include Data Trust or a similar business partner, a third party that co-sponsors a promotion, data aggregators, advertisers, media buying agencies, advertising networks, analytics providers and advertising service providers.
- From page creators, political campaigns and political committees.
- Social media sites, including Facebook, Twitter, YouTube, Pinterest, Snapchat and Instagram.
- Third-party sites, including those that allow you to integrate your third-party account with your TS account.

HOW WE USE YOUR INFORMATION

Here are more details and examples regarding how we may use your personal information:

To Improve Voter Modeling or Scoring.We, or our business partners or service providers, may use your information to improve the effectiveness of delivering political communications and to create better voting profiles.
To Provide Our Platform and Services.This could include facilitating and processing your contributions or other transactions.

To Provide Political Communications.We, political committees or campaigns, or page creators that use our Platform, or other third parties may contact you about your contribution, or the candidate, political committee or campaign to whom you contributed or other candidates, campaigns or issues that may be of interest to you.
To Improve Our Products and Services.We may use your information to make our Platform, products and services better. We may also use your information to customize your experience with us.
To Understand Your Interests.For example, we may use your information to better understand what campaigns, candidates, issues or products interest you.
To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion.
To Communicate With You.We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions. Page creators, political committees or campaigns that use our Platform may also contact you.
For Marketing Purposes. We might use your information to serve you ads or remind you to make or complete a contribution. We might tell you about new features or updates. We, our partners, or page creators, political committees or campaigns, may also use your information to send you electronic communications. This may include reminders if you visit the Platform but do not make a contribution. We and our partners may engage in cross-contextual advertising using information gathered across multiple websites, devices, or other platforms. For more information about your choices related to these communications, see the Choices section below.
For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform.
To Combine Information. For example, we may combine information that we collect offline with information we collect through our Platform, combine information we collect about you from the different devices you use to access our Platform, or combine information we get from third parties with information we already have about you.
As Otherwise Permitted By Law or As We May Notify You.
As Directed By You.

HOW WE DISCLOSE YOUR INFORMATION

Here are more details and examples regarding how we may disclose your personal information:

Internally.We may disclose your information within TS and with our parent companies and subsidiaries, and they may use and disclose your information as described in this Policy.
On Our Platform.For example, we may display information about your contributions. This may include your name and city along with the amount contributed and candidate. We may also display information, including user-generated content, that you submit in connection with a promotion.
With Page Creators, Political Committees and Campaigns. TS facilitates contributions to various political committees and campaigns through pages that are created by page creators, political committees or campaigns. As part of our service to page creators, political committees and campaigns, they receive any information collected about their contributors or other contributors through the Platform. Page creators, political committees and campaigns may use your information for all of the purposes described in this Policy. They may also use your information for purposes described in their own privacy policies. Page creators, political committees and campaigns may also disclose, sell, lease, rent or exchange your information with other political committees, campaigns or other third parties. Page creators, political committees, campaigns, or third parties that receive your information from page creators, political committees or campaigns may send you political communications or other marketing communications, and may use your information for purposes including the promotion of the Republican Party. We do not control how page creators, political committees or campaigns collect your personal information through the Platform or use or disclose this personal information.
With Our Business Partners.For example, we may disclose your information to Data Trust or a similar business partner, and your information may be used for purposes including voter identification and advocacy initiatives. Such business partners may also disclose your information to other third parties, including political committees and campaigns, for these purposes. We may also disclose your information to a third party that co-sponsors a contest or promotion. We may also disclose information to data aggregators, advertisers, media buying agencies, advertising networks, analytics providers, and advertising service providers.
With Our Service Providers.We may disclose your information to third parties who perform services on our behalf. For example, this may include merchandise vendors and payment processors. It may also include companies that send communications on our behalf or help us run, analyze or improve our Platform.
With Third Parties for Marketing Purposes.This may include political committees or campaigns of candidates that may be of interest to you. These third parties may also disclose your information to others. These third parties may use your information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.

With Any Successors to All or Part of Our Business.For example, if TS merges with, acquires or is acquired, or sells part of its business to another business entity. This may include an asset sale, corporate reorganization or other change of control.
To Comply With Campaign Finance Laws.Campaign finance law may require the submission of your name, address, occupation, and employer information along with details of your contribution to the recipient of your contribution and the reporting of this information to the Federal Election Commission (“FEC”) or relevant state or local election authority. Each political committee or campaign receiving your contributions may also include this information in their regulatory reports. FEC reports containing this information are publicly available from the FEC website.
To Comply With Other Laws or To Protect Ourselves.For example, this could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests it. We might disclose information when we are investigating a potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also disclose information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
For Other Reasons We May Describe to You.
As Directed By You.

CHILDREN UNDER 18

The Platform where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 18, and we strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 13 has provided us with information, please submit a request via ouronline webform. Parents, you can learn more about how to protect children’s privacy onlinehere.

CHOICES REGARDING YOUR INFORMATION

You have certain choices about how we use your information. Certain choices you make are browser- and device-specific.

Marketing Communications:

TS does not make calls or send text messages for marketing purposes. You can opt out of receiving our email marketing communications by following the instructions included with the communication. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

Communications from Political Committees, Campaigns and Other Third Parties:

Page creators, political committees, campaigns and other third parties may send you communications via email, call or text and they are solely responsible for complying with all applicable laws related to these communications. If you wish to opt out of receiving marketing communications from any third party, please contact that third party directly to do so. For text messages, you can try to reply STOP to text messages in order to unsubscribe, although we cannot guarantee that this will be effective. Please note that “opt out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to process.

Cookies & Other Tracking Activities:

For information on our use of tracking technologies, and your ability to control these technologies, or to read our “Do Not Track” policy, please visit our About Ads policy at https://winred.com/about-our-ads/.

YOUR PRIVACY RIGHTS

For residents of California, Colorado, Connecticut, Virginia and Utah, you may have the rights listed below with respect to the Personal Information that we maintain about you. Nevada residents have the right to request to opt out of the sale of personal information.

We may take steps to verify your identity, as permitted or required under applicable law, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

Please note that we do not knowingly share for cross-contextual marketing purposes or sell the Personal Information of individuals who are under 18 years old.

Notice. This means that you can request that we disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of Personal Information we have collected about the consumer.
Deletion. This means that you can request that we delete personal information about you that we have collected from you.
Correction. This means that you can request that we correct inaccurate personal information that we maintain about you.
Opt Out of Sale of Personal Information. This means you can request to opt out of the “sale” of your personal information, as this term is defined under applicable state law.
Opt Out of Sharing of Personal Information. This means you can request to opt out of sharing of personal information with third parties for cross-contextual marketing purposes.
Right to Non-Discrimination. This means that we are prohibited from discriminating against you if you exercise your rights under applicable law.

Agents that you have authorized to act on your behalf may also submit requests as instructed below. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.
Individuals who wish to exercise their rights under this section can submit a request via our online webform. If we deny your rights request and you would like to appeal, you may contact us at legal@winred.com.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS: If you reside in California, you have the right to ask us one time each year whether we have shared personal information with third parties for their direct-marketing purposes. To make a request, please submit a request via our online webform.

SECURITY

The Internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal information under our control. A user ID and a password are needed to access certain areas of the TS Platform. It is your responsibility to protect your username and password. If your password has been compromised, you are required to notify us and change your password.

STORAGE OF INFORMATION

Information we maintain may be stored in or outside of the United States. This Platform is intended for use by individuals who are located in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country. If you are located outside of the United States, you understand and agree that we may transfer your personal information to the United States.

LINKS

Our Platform may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third-party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third-party sites.

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at winred.com/contact or by telephone at 1 888-288-1890. You may also write to us at the following address:

WinRed Technical Services, LLC

4250 Fairfax Dr

Suite 600

Arlington, VA 22203

CHANGES IN POLICY

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.

Privacy Policy

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