Last revised June 1, 2020
Action Network — made up of Action Network and Action Squared, Inc. (“we,” “us,” or “our”), values your privacy. The Privacy Notice explains who we are, how we collect, share and use Personal Information about you, and how you can exercise your privacy rights. This Privacy Notice applies to Personal Information that we collect through our websites at https://actionnetwork.org and https://actionbuilder.org (“the Sites”) or Site-embedded functionality. We will never sell or share your Personal Information outside of what you allow through normal use of the Sites.
- Partner Information
- Information We Collect
- How We Use Information
- How We Share Information
- Cookies & Other Tracking Tech
- Third Parties Collecting Information
- Keeping Information Secure
- Your Choices for Information Usage
- Changes to Your Information
- Your Information Rights
- Visitors Outside the U.S.
- Information Retention
- Legal Basis for Information Processing (EEA Visitors)
- Children Under Age 13
- Changes to this Notice
- Contact Us
This Privacy Notice (the “Notice”) applies only to the Sites. If you click on a link to another website from one of the Sites, the Notice will not apply to the information collected on that website. Action Network has no control over such third party websites and will not be held responsible or liable, directly or indirectly, for any damage or loss caused or alleged to have been caused by or in connection with the use of or reliance on any content, advertising, products, or other materials on or available from such websites, nor from any information that you provide to such websites or that such websites collect from you.
The Notice applies to our collection and use of Personal Information, which means any information that we collect relating to an identified or identifiable natural personal, including, but not limited to, an individual’s name, address, email address, telephone number, Social Security Number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information (“Personal Information”).
Personal Information does not include “aggregate” information, which is data collected about the use of the Sites or about a group or category or services or users, from which individual identities or other Personal Information has been removed and cannot be identified. The Notice does not restrict or limit our collection and use of aggregate information.
In most circumstances we are a data processor following the instructions of our third-party partners, the data controllers; for example when you use one of our services to take an action (i.e., signing a petition) organized by one or more of our third-party partners, our partners will be the data controller. Information you submit as part of the form filling process will be made available to the data controller directly. We have no ability to control, and shall have no responsibility for, how such data controllers use your information. We will not review, share, distribute, or reference any Personal Information controlled by our third-party partners, except as provided in our agreement with our third-party partners, or as may be required by law.
For purposes of this Privacy Notice and the obligations of Action Network and Action Squared, Personal Information does not include information controlled by our third-party partners (“Third-Party Personal Information).
Information We Collect
Information you may voluntarily provide when you use the Sites
You may voluntarily provide Personal Information to us when you:
- Create an account/profile (e.g. your full name, address, and email address) as a third-party partner
- Enter your username/password
- Arrange to make payments for use of our services
- Fill out a form
- Fill out a survey
- Conduct searches on the Sites
- Sign up to receive email or text message alerts/updates (e.g. email address, phone number)
Please note that information we collect may vary, depending on whether you are visiting the Action Builder Site or the Action Network Site.
Information automatically collected when you visit and use the Sites
When you visit the Sites, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area (“EEA”), this information is considered Personal Information under applicable data protection laws.
Specifically, the information we collect automatically may include:
- Your computer’s IP address
- Your browser type and operating system
- Your bandwidth speed
- Information about the software programs that are installed on your computer
- Web pages you were visiting immediately before and after you visited the Sites
- Web pages that you view and links that you click on within the Sites
- Standard server log information
- Information collected through cookies
- If you access the Sites through a mobile device, the type of mobile device, your device’s unique ID, the type of mobile Internet browser and operating system you use, and the location of your device
Information that we collect from other sources
We may access information about you from third-party sources and platforms. This information may include:
- Unique identifiers, including mobile device identification numbers, that can identify the physical location of such devices in accordance with applicable law
How We Use Collected Information
We may use the collected information in various ways to provide our services and for our business purposes (and, note that our uses and purposes may differ between the Action Network and Action Builder platforms), including, but not limited to:
- Sending email or other electronic communications to our third-party partners
- Fulfilling requests for services and information from our third-party partners
- Supporting the processing of payments by a payment processor
- Preventing illegal activities, enforcing the Sites’ Master Terms, and otherwise protecting our rights and the rights of our third-party partners
- Developing internal analytics and to improve the quality and relevance of the Sites to our visitors
- Maintaining and improving the accuracy of the records we hold about you
- Maintaining information for short-term, transient use
How We Share Collected Information
We will only make Personal Information about users available to third parties as describes below:
- To trusted third-party service providers, including vendors and consultants, employed to perform Site-related services, including database management, web hosting, maintenance services, analytics, data processing, geolocation, technical support-services, credit card processing, security services, and email and text message distribution
- To any competent law enforcement body, regulatory, government agency, court or other third party to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, violations of the Master Terms, or as otherwise required by law
- When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal process or respond to lawful requests, claims or legal authorities, including lawful subpoenas, warrants, or court orders
- As permitted under the terms in place with our third-party partner
- To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your Personal Information only for the purposes disclosed in this Privacy Notice
- To any other person with your consent
We may share aggregate information with third parties to help us develop content or services.
To customize your experience on the Sites, we provide you with the opportunity to access or interact with third-party services, such as Facebook and Twitter. When you connect to one of the Sites through these third-party services, we may share Personal Information about you with these third-party service providers.
We may use data that we receive from third-party service providers to:
- Enhance and personalize your experience on the Sites (e.g. display your profile picture)
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us annually for a notice identifying the categories of Personal Information which we share with our affiliates and/or third-parties for marketing purposes and to provide contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: email@example.com. Note, however, that we do not disclose users’ Personal Information to third parties for marketing purposes as defined in the statute.
Cookies & Other Similar Tracking Technologies
As is standard practice on many websites, we may set and access cookies, web beacons, Flash cookies, and other similar tracking technologies (collectively, “Cookies”) on your computer. Cookies are small amounts of information stored in files within your computer’s browser. For further information about Cookies we use, why, and how you can control cookies please see our Cookies Notice.
Collection of Information by Third Parties
Please note that third-party ad networks, advertising agencies, advertisers, and audience segment providers and other companies (e.g. Google DoubleClick, Yahoo Tremor, and 24/7 RealMedia) may also set and access Cookies on your computer when you visit the Sites.
How We Keep Personal Information Secure
We use appropriate technical and organizational measures to protect the Personal Information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. Specific measures we use include encryption of data in transit and at rest, industry-standard development practices and software update policies to keep software up to date and secure, use of web application firewalls and other security tools, regular security audits and scans, and logging and monitoring of access to Personal Information.
Your Choices Regarding the Collection and Use of Your Information
To reduce the amount of Personal Information that we collect from you and limit its use, you can take one or more of the following steps:
- Opt-out of receiving emails from us, by clicking the unsubscribe link in emails you receive from us
- Opt-out of allowing us to collect your geographic location by changing the location settings on your mobile device
You can find information about how to opt-out of or reject Cookies in our Cookies Notice.
Changes to Your Information
To change any Personal Information that you provided as part of your account, click here.
We respond to all requests from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
As described in this Notice, if you are using the Sites through one of our third-party partners (e.g. the Organization organizing an action) then we are the processor of your Third Party Personal Information and our partner is the data controller. In such cases, if you want to exercise any data protection rights above or have questions or concerns about how your Third Party Personal Information is handled by us as a processor on behalf of our third-party partners, you should contact the relevant partner that has contracted with us, and refer to their separate privacy notices.
Because we have a limited ability to access Third Party Personal Information that our third-party partners submit to the Sites or that you submit to the partner on one of the Sites, if you wish to make your request directly to us, please provide the name of the third-party partner who submitted your Third Party Personal Information to one of the Sites or who you submitted Third Party Personal Information to on one of the Sites. We will refer your request to that partner, and will support them as needed in responding to your request within a reasonable timeframe.
If you are a visitor from the European Economic Area (“EEA”) using the Action Network tool (Action Builder is currently unavailable for use by EEA-based users), you have the following data protection rights:
- If you wish to access, correct, update, or request deletion of Third Party Personal Information, you can do so at any time by contracting the partner who is the controller for your information, or by contacting us at firstname.lastname@example.org with the name of the third-party partner and we will forward your request to them, as described above.
- In addition, you can object to processing of your Third Party Personal Information, restrict processing of your Third Party Personal Information or request portability of your Third Party Personal information by contacting the third-party partner who controls your Third Party Personal Information, or contact us as email@example.com with the name of the third-party partner and we will forward your request to them, as described above.
- If you wish to withdraw consent to use Third Party Personal Information, please contact the third-party partner you controls your Third Party Personal Information, or contact us at firstname.lastname@example.org with then name of the third-party partner and we will forward your request to them, as described above.
- You have the right to complain to a data protection authority about the collection and use of your Third Party Personal Information. For more information, please contact your local data protection authority. For UK users, this is the Information Commissioner’s Office. Contact details for data protection authorities in the EEA, Switzerland, and certain non-European countries (including the US and Canada) are available here.
Under the California Consumer Privacy Act (“CCPA”), if we are collecting your information on behalf of a third-party partner covered by the CCPA, you have the right to request that your information be deleted. Please contact the third-party partner who controls your Third Party Personal Information or contact us at email@example.com.
Visitors From Outside the United States
Our offices and data processing equipment are located in the United States. If you visit one of the Sites from another country, please be aware that information you provide to us or that we obtain through your use of the Sites may be transferred to and processed in the UnitedStates and will be subject to United States law. United States privacy and data protection laws may not be equivalent to laws in your country of residence.
We have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Notice. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of Third Party Personal Information with our third-party service providers and partners, which require all parties to protect Third Party Personal Information they process from the EEA in accordance with European data protection law. Further details can be provided upon request.
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so, including: to provide you with a service you have requested, to provide our third-party partners with a service they have requested, or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it. If this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
Where we are processing Personal Information on behalf of one of our third-party partners, we will do so as instructed by our partner.
Legal Basis for Processing Information (for Visitors From the EEA)
If you are a visitor from the EEA using the Action Network tool (Action Builder is currently unavailable for use by EEA-based customers), our legal basis for collecting and using personal information depends on the specific context in which we collect it.
For all the data collected where we are acting as processor of so-called Third Party Personal Information, our third-party partner makes the determination.
Where we are acting as a controller of data, we will normally collect Personal Information from you only (i) where we need the Personal Information to perform a contract with you, (ii) where the processing is in our legitimate interest and not overridden by your rights, (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect Personal Information from you.
If we collect and use your Personal Information in reliance on our legitimate interests, this interest will normally be to operate the Site and service, communicating with you as necessary to provide our services, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us.
Children Under Age 13
We encourage parents to monitor their children’s Internet usage and caution them about the dangers of personal information on the Internet. Children under age 13 should not visit the Sites on their own and should not submit any Personal Information to the Sites. We do not knowingly collect Personal Information from children under age 13. If we learn that we have collected any Personal Information from a child under age 13 without verifiable parental consent, we will delete that information from our database as soon as possible.
Changes to the Privacy Notice
We may update the Notice at any time to reflect changes in our practices. If we modify the Notice, we will place a prominent notice on the Sites or take other appropriate measures to inform you, consistent with the significance of the changes we make as we determine in our sole discretion. As part of any modification of the Notice, we will update the “last revised” date at the top of this Notice.
If you have any questions or concerns about, or want to exercise your rights under the Notice, please contact firstname.lastname@example.org.
If you are a visitor from the EEA and need to get in touch with our Data Protection Officer, please contact email@example.com.
If you are an EEA visitor the data controller of your Personal Information is Action Squared, Inc. or our relevant partner.