Effective Date: June 18, 2019
Last Updated: March 2, 2020
WHAT’S NEW? We have incorporated updates related to the new feature on our Platform that allows page creators (as defined below) to create contribution pages. Please review this document carefully to understand the updates.
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 use or share your information. For more details about how page creators, political committees and campaigns may use and share your information, pleaseclick here.
This Platform is intended for use by individuals who are located in the United States.
TYPES OF INFORMATION WE COLLECT
TS collects information from you and about you. Here are some examples of the information we may collect:
- Contact Information.For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
- Political Affiliation Information.For example, we may collect information about your political party affiliation and opinions and candidates or political issues that interest you.
- 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.
- Contribution Information.For example, we may collect information about the amount of contributions you make and the candidates you support. We may publically post on our Platform your first name, your city and state, the amount of your donation and the candidate you support.
- Payment Information.For example, we may collect your billing address and payment card type and expiration date.
- Account Information.If you create an account on our Platform, we may collect your username and password.
- Information You Post.We may 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.
- 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.
- Employment Information.For example, we may collect information about your employment status, employer and occupation. We may also ask whether you are retired.
- Information You 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. Some political committees or campaigns that use our Platform may ask you to submit other types of miscellaneous information. This may include various petitions, forms, and surveys.
- Demographic Information.We may collect your birthdate, age, gender and zip code. We may also collect information that could identify you and relates to your hobbies, interests and political affiliation.
- Device Information.For example, we may collect the type of device you use to access our Platform. We may also collect your device identifier, IP address, or operating system.
- Other Information.In addition, if you use our Platform, we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us.
HOW WE COLLECT YOUR INFORMATION
TS collects your information in different ways. Below are some examples of how we may collect your 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.
- Passively. For example, we may passively collect 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. Third parties 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 similar organizations, our online advertising networks, analytics vendors, companies that co-sponsor our promotions, and political committees, campaigns or other political contribution sites.
- 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.
- By Combining 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.
- Combine information we get from third parties with information we already have about you.
HOW WE USE YOUR INFORMATION
Examples of how we may use your information include:
- 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 about specific candidates 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, including through email or text message. This may include reminders if you visit the Platform, but do not make a contribution. We and our partners may engage in interest-based 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.
- As Otherwise Permitted By Law or As We May Notify You.
HOW WE SHARE YOUR INFORMATION
We may share your information in the following ways:
- Internally.We may share your information within TS and with our parent companies and subsidiaries, and they may use and share 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, we may share with them 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. Page creators, political committees and campaigns may also share, 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.
- With Our Business Partners.For example, we may share your information with 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 share your information with third parties, including political committees and campaigns, for these purposes. We may also share your information with a third party that co-sponsors a contest or promotion. We may also share information with data aggregators, advertisers, media buying agencies, advertising networks, analytics providers, and advertising service providers.
- With Our Service Providers.We may share your information with 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 our Platform.
- With Third Parties for Marketing Purposes.This may include political committees or campaigns of candidates thatmay be of interest to you. These third parties may also share your information with 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 report this information in reports to the Federal Election Commission (“FEC”). 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 theFEC 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. We might share information when we are investigating a potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also share 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.
CHILDREN UNDER 13
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 13, 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 contact us at [email protected] You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-linehere.
CHOICES REGARDING YOUR INFORMATION
ou have certain choices about how we use your information. Certain choices you make are browser and device specific.
You can opt out of receiving our 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:
You may have the opportunity to sign-up to receive communications from page creators, political committees, campaigns and other third parties. If you wish to opt out of receiving marketing communications from any third party, please contact that third party directly to do so. 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.
YOUR CALIFORNIA PRIVACY RIGHTS
If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at [email protected] or write to us at the address listed below. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.
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.
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.
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 [email protected] or by telephone at 1 888-288-1890. You may also write to us at the following address:
WinRed Technical Services, LLC
1776 Wilson Blvd
Arlington, VA 22209
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.
© WinRed Technical Services, LLC. 2020.