Democracy Counts!, Inc.
Version date: October 26, 2020
Your privacy is critically important to us. At Democracy Counts!, Inc., we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We aim to make it as simple as possible for you to control what information about you is shared publicly (or kept private), indexed by search engines, and permanently deleted.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
Who We Are and What This Policy Covers
- Our mobile applications (including Actual Vote and Wanna Vote);
- Our website-based analytic interfaces
- Our community platform(s) (such as Scrutineers.org) in which we work with you to implement our election security tools and receive your feedback on how to improve them;
- Our community fundraising platform (hosted on Mighty Cause); and
- Affiliates’ websites and services that connect to our Services while you are logged in to your account with us.
Creative Commons Sharealike License
Information We Collect
We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:
- Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for an Actual Vote account to provide an email address and password, along with a username or your name — and that’s it. You may provide us with more information — like your address and other information you want to share — but we don’t require that information to create an Actual Vote account.
- Public profile information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a Scrutineers account, your username is part of that public profile, along with any other information you put into your public profile, like a photo or an “About Me” description. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
- Payment and contact information: If you buy something from us, we’ll collect information to process those payments and contact you. If you make a donation to us (for example via Recurring Payments or Simple Payments), you’ll provide additional personal and payment information like your name, credit card information, and contact information. We will keep a record of the purchases and donations you’ve made. If you are an affiliate organization raising money on Mighty Cause under our 501(c)(3) authority, you may also provide us with financial details to set up a payments integration, like the email address for your Stripe or PayPal account or your bank account information, and your tax I.D.
- Content information: You might provide us with information about you in draft and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
- Credentials: Depending on the Services you use, you may provide us with credentials for your self-hosted website (like SSH, FTP, and SFTP username and password).
- Communications with us (hi there!): You may also provide us with information when you respond to surveys, communicate with our Techies about a support question, post a question in our public forums, or sign up for a newsletter like the one we republish on our website DemocracyCounts.org. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
- Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.
Information We Collect Automatically
We also collect some information automatically:
- Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services, and we collect identifying and verification data about the election-audit data stored on your mobile device.
- Usage information: We collect information about your usage of our Services. For example, we collect information about who did what and when (e.g., “username” deleted “video identifier” at “time/date”). We also collect information about what happens when you use our Services (e.g., page views, support document searches at DemocracyCounts.org, features enabled for your profile (such as stickers), interactions with our Techies and other parts of our Services, along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
- Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a video of a poll tape with location information).
- Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, in order to use Actual Vote you must give us permission to access the photographs on your mobile device’s camera roll, and our Services will access the photos stored on your device when you upload a video of a poll tape to our secure server for comparison with official results.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you connect your account to a social media service (like Twitter or Ello) we’ll receive information from that service (e.g., your username, basic profile information, friends list) via the authorization procedures for that service. The information we receive depends on which services you authorize and what options are available. Third-party services may also give us information, like mailing addresses for individuals who are not yet our Citizen Auditors (but we hope will be!). We may use this information for marketing purposes like postcards and other mailers promoting citizen action and our Services.
How and Why We Use Information
Purposes for Using Information
We use information about you for the purposes listed below:
- To provide our Services. For example, to set up and maintain your account, upload election audit data you collect, provide customer service, process payments and orders, and verify user information.
- To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them perform their Citizen Audit tasks or make our Services easier to use.
- To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our Citizen Auditors (like those who have been Citizen Auditors for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people donated after receiving a marketing message), and understanding and forecasting user retention.
- To protect our Services, our Citizen Auditors, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Democracy Counts and others, which may result in us, for example, declining a transaction, quarantining or destroying uploaded data, or terminating Services.
- To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
- To customize the user experience. For example, to personalize your experience by serving you relevant notifications for our Services, recommending content that may enhance your experience as a Citizen Auditor, and providing new essays and stories about citizen-powered election audits for your reading pleasure.
- To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Democracy Counts; texting you to verify your payment or donation; or calling you to share volunteer opportunities that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
- To recruit and hire new Democracy Counts team members. For example, by evaluating job applicants and communicating with them.
Legal Bases for Collecting and Using Information
How We Share Information
We share information about you in limited circumstances, and with appropriate safeguards on your privacy. (We do not do this at this time, but if and when we begin they will be spelled out below, as well as in a policy document called Ads and Analytics Services Provided by Others.)
- Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you. This includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, registrars, and registries); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations; and companies that make products that we may make available on our website, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.
- Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Democracy Counts, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so, like when you connected your site to a social media service.
- Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.
Our policy is to not sell our users' data. We aren't a data broker, we don't sell your personal information to data brokers, and we don't sell your information to other companies that want to spam you with marketing emails. We may show ads on some of our services, and the revenue they generate would let us offer free access to some of our Services so that money doesn’t become an obstacle to having a voice. Under a new California law, the California Consumer Privacy Act ("CCPA"), some personalized advertising you see online and on our services might be considered a "sale" even though we don't share information that identifies you personally, like your name or email address, as part of our advertising program. (If we begin to do this, we will provide information about your choices concerning these ads.)
Information Shared Publicly
Information that you choose to make public is — you guessed it — disclosed publicly. That means information like your public profile, posts, and photos and other content that you make public on your profile (if you make it public). Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share publicly.
How Long We Keep Information
We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — providing that we’re not legally required to keep it. For example, we keep the web server logs that record information about a visitor to one of Democracy Counts’ websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Democracy Counts’ websites and investigate issues if something goes wrong on one of our websites. As another example, when you delete a post, comment or sticker that you posted from our Service to your social media accounts, it stays in your Trash folder for thirty days in case you change your mind and would like to restore that content, because starting from scratch is no fun. After the thirty days are up, the deleted content may remain on our backups and caches until purged.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks. To enhance the security of your account, we will enable and recommend our advanced security settings, like Two Step Authentication (these are not operative yet).
You have several choices available when it comes to information about you:
- Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
- Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs, which will handicap your effectiveness as a Citizen Auditor.
- Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
- Set your browser to reject cookies: At this time, Democracy Counts does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Democracy Counts’ websites, with the drawback that certain features of our websites may not function properly without the aid of cookies.
- Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.
European General Data Protection Regulation (GDPR)
If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You also have the right to make a complaint to a government supervisory authority.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is.
We may collect the following categories of personal information from California residents, depending on the Services used:
- Identifiers (like your name, contact information, and device and online identifiers);
- Commercial information (your billing information and purchase history, for example);
- Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
- Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an administrator of an election audit team);
- Geolocation data (such as your location based on your IP address or geotags attached to photographs and videos that you take as part of your election audit activities);
- Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
- Professional or employment-related information (for example, information you provide in a job application); and
- Inferences we make (such as likelihood of retention or attrition).
You can find more information about what we collect in the Information We Collect section above. We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:
- Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
- Request deletion of personal information we collect or maintain;
- Opt out of any sale of personal information; and
- Not receive discriminatory treatment for exercising your rights under the CCPA.
The CCPA & Personalized Advertising in Our Ads Program
Contacting Us About These Rights
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, use our Contact form. When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.
Controllers and Responsible Companies
Democracy Counts’ Services will eventually be worldwide. Different affiliate companies are the controllers (or co-controllers) of personal information, which means that they are the company responsible for processing that information, based on the particular service and the location of the individual using our Services. Depending on the Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is Democracy Counts, which entered into the contract with you under the Terms of Service for the product or service you use. Eventually, in order to serve our international users more effectively, we may set up subsidiary companies or contract with affiliates to become the controller for some of the processing activities across all of our Services worldwide. The chart below explains the controllers for processing your personal information.
Democracy Counts!, Inc. 2227 29th Street, San Diego, CA 92104
How to Reach Us
Other Things You Should Know (Keep Reading!)
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
Ads and Analytics Services Provided by Others
That’s it! Thanks for reading.