Privacy Policy & Terms of Use

Last updated: June 26, 2023

 

1.     INTRODUCTION

True Blue Analytics (“We” or “Us”) operates the website [trueblueanalytics.org] (the “Site”).  We also provide data services to our clients.

By logging into this website and using the Site, you agree to be legally bound by this Privacy Policy and Terms of Use.  You also agree to be bound by other legal notices that may be posted on this Site from time to time.  We collect certain Personal Information about individuals from third-party sources that may be sold to our clients.

We are committed to protecting your privacy online. By providing Personal Information to us, you agree to these Terms.  The Site is directed to users in the United States only.

2.     UPDATES TO THE TERMS

Please review these Terms periodically because we modify it from time to time. 

Please look at the “LAST UPDATED” legend at the top of this page to see when these Terms were last revised. Any changes to these Terms will become effective when we post the revised Terms on the Site.  Each time you visit this Site or provide us with information through the Site, by doing so you are accepting practices described in the Terms in effect at that time.

3. INTELLECTUAL PROPERTY RIGHTS

All copyright and other rights in and to the computer programs, computer applications, web applications, database programs, web content files and all written, graphic, audio and audiovisual works incorporated into and utilized on or a part of the Site and/or Site will be and remain the sole and exclusive property of True Blue Analytics (“Intellectual Property”).

You may not copy, modify, publish, transmit, distribute, perform, display, or sell any such Intellectual Property.

4.     YOUR PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual, such as but not limited to: 

  • Name

  • Email address 

  • Zip Code

We may collect information you give us when you interact with our site or contact us. We do not collect credit or debit card information.

 

5.     HOW WE USE PERSONAL INFORMATION

We may use Personal Information:

  • For our own purposes, such as data analysis, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our services.

  • For provision to our clients.  We require that our clients’ use of any data received from us will be in compliance with applicable data protection laws and industry best practices.

  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

6.     HOW PERSONAL INFORMATION IS DISCLOSED

Your Personal Information may be disclosed:

  • To our clients, to be used by non-profit organizations and political organizations in their marketing, fundraising, customer service, and constituent service and outreach programs.

  • To our third-party service providers who provide services such as website hosting, data analysis, donation and payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, auditing services and other similar services to enable them to provide services.

  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets (including in connection with any bankruptcy or similar proceedings).

  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. 

7.     STATE-SPECIFIC RESTRICTIONS

a.     Additional Privacy Information For Nevada Users

Notice to Nevada Residents: Nevada Senate Bill 220 provides consumers (Nevada residents) with specific rights regarding their Personal Information. This section describes your Nevada privacy rights and explains how to exercise those rights.

 i. Right To Opt Out

You have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”).

To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us using the web form hosted on [trueblueanalytics.org] or by calling 202-713-9262.

 ii. Response Timing and Format

We endeavor to respond to a verifiable consumer request within sixty (60) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically. 

b.    Additional Privacy Information For California Users

Notice To California Residents: The California Consumer Privacy Act of 2018 (“CCPA”) provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

 Please make sure you also consult the rest of our general privacy policy above for complete information.

i. Access to Specific Information and Data Disclosure Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Section iii below) we will disclose to you:

  • The categories of Personal Information we collected about you.

  • The categories of sources for the Personal Information we collected about you. 

  • Our business or commercial purpose for collecting or selling that Personal Information.

  • The categories of third parties with whom we share that Personal Information.

  •  If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: 

    • sales, identifying the Personal Information categories that each category of recipient purchased; and

    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

ii. Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.

Once we receive and confirm your verifiable consumer request for deletion (see Section iii below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  •  Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  •  Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

iii. Exercising Access, Data Disclosure, and Deletion Rights

To exercise the access, data disclosure and deletion rights described above, please submit a verifiable consumer request to of the below methods: 

  • Using the web form hosted on [trueblueanalytics.org/privacy-policy]

  • Emailing us at privacy@trueblueanalytics.org.

  • Calling us at 202-713-9262.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

  • You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

  • We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

  • Making a verifiable consumer request does not require you to create an account with us.

  • We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 iv.  Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response electronically.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

v. Personal Information Sales Opt-Out and Opt-In Rights

You have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”). Users who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us by:

  • Using the web form hosted on [trueblueanalytics.org/privacy-policy]

  • Emailing us at privacy@trueblueanalytics.org. 

  • Calling us at 202-713-9262.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into Personal Information sales at any time by contacting us at the email address or phone number provided in this notice. 

You do not need to create an account with us to exercise your Right to Opt-Out. We will only use Personal Information provided in an opt-out request to review and comply with the request.

vi. Non Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services. 

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 vii. Other California Privacy Rights

As referenced in this policy, we may from time to time elect to share certain information about you collected by us on the Service with third parties for those third parties’ direct marketing purposes.  

California Civil Code Section 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes.

To make such a request, please email us at privacy@trueblueanalytics.org, or calling us at 202-713-9262.

c.     For Colorado Residents:

1. How We Collect Your Data.

True Blue Analytics collects personal information about you in a number of ways:

  • Online via various methods

To comply with Colorado data protection rules True Blue Analytics will always ensure we have legal justification for collecting and using your personal information.

The legal basis that we rely on will depend upon the circumstances in which we collect and use your personal information. In almost all cases, our processing of your personal information will fall into one of the following categories:

  • Where you have provided your consent to allow us to use your data in a certain way. We will not collect or process Sensitive Data without obtaining your consent.

  • Where it is necessary for us to process your data in order to comply with a legal obligation.

  • Where it is in our legitimate interests to contact you in order to raise funds and achieve our campaign objectives. Where we rely on a legitimate interest to use your information, we will always ensure that this is done in a way so as not to be intrusive or cause distress, and that respects your rights.

  • Where it is necessary for us to process your data in order to carry out the performance of a contract with you.

  • Where it is necessary to protect your vital interests or the vital interests of another individual.

  • Where it is necessary to conduct internal research or perform internal operations that are needed to develop our products, services, or technology; or ensure functionality and fulfillment of the user’s expectations based on our existing relationship.

2. The data is provisioned for and sold to Democratic campaigns, political action committees, non-profits, and other aligned or progressive organizations for the purposes of fundraising solicitation and other activism.

3. Your Rights Under the Colorado Privacy Act

a. The right of access – you have the right to confirm whether a controller is processing your personal data and to access that data.

b. The right of correction – you have the right to require controllers to correct inaccuracies in your personal data.

c. The right of deletion – you have the right to require controllers to delete your personal data.

d. The right of portability – up to twice a year, you have the right to obtain your personal data in a portable and readily usable format that allows you to transmit the data to another entity without hindrance.

e. The right to opt-out – you must be provided with the ability to opt out of the processing of your personal data for purposes of targeted advertising, sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.

f. The right to appeal – you have the right to appeal a controller’s action or inaction in response to your exercise of your rights.

You may exercise these rights by contacting us by the methods indicated in Section 5.

4. Our Obligations as a Data Controller

As a Controller under the Colorado Privacy Act, True Blue Analytics fulfills its obligations to you as a resident of Colorado, in the following ways:

  • We fulfill our Duty of Transparency to you by providing this comprehensive Privacy Policy and notice of any material changes to this policy.

  • We fulfill our “Opt-In” Duty by first obtaining your consent before processing any Sensitive Data, and providing ways to easily withdraw your consent for Targeted Advertising, Profiling, and the like by filling out the form found in the footer of our website.

  • We fulfill our Duty of Care to you by taking reasonable security precautions during storage, only using data in the ways described in this policy, and conducting data protection assessments as required. All third-parties with access to your personal data are contractually required to uphold and abide by the obligations and practices in this policy.

  • We fulfill our Duty to Minimize Data by limiting our collection of your data to only what is relevant and necessary in relation to the purposes specified in this policy.

  • We fulfill our Duty to Specify the Purposes of your data collection and processing by providing this information in this policy.

  • We fulfill our Duty to Avoid Secondary use by only collecting and processing your data according to the purposes specified in this policy or for which your consent was obtained.

  • We fulfill our Duty to Avoid Unlawful Discrimination by never processing your data in any way that could violate state or federal laws prohibiting unlawful discrimination against consumers.

  • We fulfill our Duty to Provide the Ability to Appeal by establishing internal processes that allow you to appeal our decisions to take or refuse to take action on your requests to exercise your rights under the applicable law here by filling out the form found in the footer of our website

Any individual or entity processing data we control will be contractually bound to assist us in meeting our duties and obligations to you under the Colorado Privacy Act.

5. How to change your communications preferences, or learn more.

True Blue Analytics operates in accordance with all relevant data protection laws. If you would like to find out more about these laws and how you could be affected beyond what is mentioned in this privacy policy, please visit the Colorado Attorney General’s Website.

If you have any specific questions about how True Blue Analytics controls or processes your data which are not answered here or you would like to exercise any of your rights under applicable law, please contact privacy@trueblueanalytics.org.

If you are not satisfied with our response to your inquiry then you can appeal or request further information by privacy@trueblueanalytics.org.

8.     OTHER INFORMATION

a.  OTHER INFORMATION WE COLLECT

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

  • Browser information

  • Server log files

  • Information collected through cookies, pixel tags and other technologies

  • Demographic information and other information provided by you

  • Aggregated information

b.   HOW WE COLLECT OTHER INFORMATION

We and our third party service providers may collect Other Information in a variety of ways, including:

  • Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version and Internet browser type and version.

  •  Using cookies: Cookies allow a web server to transfer data to a computer for record keeping and other purposes. We and our service providers use cookies and other technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of the Site, as well as for online tracking purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. If you choose to decline cookies, some or all of the features and functionality of the Site may not be available to you.

  • Using embedded images, pixel tags and other similar technologies: We may use embedded images or pixel tags (also known as web beacons and clear GIFs) in connection with some Site pages and email messages to, among other things, track the actions of Site users and email recipients, measure the success of our marketing campaigns and compile statistics about Site usage and response rates.

  • From you: We may collect demographic information such as your location, as well as other information, such as your preferred means of communication, when you voluntarily provide this information to us. Unless combined with Personal Information, this information does not personally identify you or any other user of the Site.

  • By aggregating information: We may aggregate Personal Information so that the end-product does not personally identify you or any other user of the Site, for example, by using Personal Information to calculate the percentage of our users who have a particular telephone area code. Aggregated Personal Information does not personally identify you or any other user of the Site.

c.     HOW WE USE AND DISCLOSE OTHER INFORMATION

Because Other Information does not personally identify you, we may use and disclose Other Information for any purpose. 

In some instances, we may combine Other Information with Personal Information (such as combining your name with your IP Address).  If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

9.     LIMITATION ON LIABILITY

We reserve the right to interrupt the operation of Site, or your use of the Site, with or without prior notice for any reason or no reason.

You agree that We will not be liable for interruption of Site or for its delay or failure to perform. We assume no responsibility for any error, omission, interruption, deletion, defect, delay in operation or transmission, telephone system or communications lines failures, or theft or destruction or unauthorized access to, or alteration of, user communications.

We are not responsible for any problems or technical malfunction of any telephone network or lines, computer systems, servers or providers, computer equipment, software, failure of email systems on account of technical problems or traffic congestion on the Internet or at any site or combination thereof, including injury or damage to users of Site or to any other person's phone or computer related to or resulting from participating or downloading materials in connection with the Site.

Except where restricted or prohibited, in no event will We be liable to you or any third person for any indirect, consequential, exemplary, incidental, special or punitive damages, including lost profits arising from your participation in the Site or use of the Site, or of our termination of your account, even if We have been advised of the possibility of such damages.

10.  SECURITY

We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure.   If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the issue by contacting us in accordance with the “Contacting Us” section below.

 

11.    ONLINE PRIVACY PROTECTION 

We comply with the California Online Privacy Protection Act.  As part of that Act, all registered users of our site may make any changes to their information at any time contacting us as described below.

12.  CHOICES AND ACCESS

a.    YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION

Unless covered by Section 7 (Nevada and California residents), we give you many choices regarding our use and disclosure of your Personal Information. You may opt out from our sharing of your Personal Information with clients for their marketing purposes. 

If you would prefer that we do not share your Personal Information on a going-forward basis with our clients for their marketing purposes, you may opt out of this sharing by contacting us at privacy@trueblueanalytics.org.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out as described above, we will not be able to remove your Personal Information from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt out request).

Please also note that if you do opt out of receiving marketing-related messages from us, we may still send important administrative messages to you, and you cannot opt out from receiving administrative messages.

b.    HOW YOU MAY ACCESS OR CHANGE YOUR PERSONAL INFORMATION

If you would like to review or update your Personal Information that has been previously provided to us, you may contact us at privacy@trueblueanalytics.org.

In your request, please make clear what information you would like to have changed. We will try to comply with your request as soon as reasonably practicable. We are not responsible for changing information from the databases of third parties with whom we have already shared your Personal Information.

13.  USE OF SITE BY MINORS

The Site is not directed to individuals under the age of thirteen, and we request that these individuals do not provide Personal Information through the Site.

We do not knowingly, directly or passively, collect information from children under the age of 13.  To respect the privacy of children and to comply with the Children's Online Privacy Protection Act, children under the age of 13 should not provide any Personal Information on this Site.  We ask that parents supervise their children while online.

14.   JURISDICTIONAL ISSUES

The Site is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

15.   CONTACTING US

If you have any questions about this Privacy Policy and Terms of Use, please contact us at privacy@trueblueanalytics.org.

Please note that email communications are not always secure, so please do not include sensitive information in your messages to us.