Website Privacy Policy
Effective: January 10th, 2025
This Privacy Policy ("Policy") governs the manner in which PolicyEngage, LLC ("we", "us", "our" or "Company"), collects, uses, maintains and discloses (collectively, "processes") Personal information (defined below) regarding you ("you" or "your") in your interaction with Company, including your use of any Company-operated website that links to this Policy and other products or services that are offered or provided by us (collectively, the "Site").
This Policy describes the types of Personal Information that the Company may process, how we may use and disclose that Personal Information, how you may exercise any rights you may have regarding our processing of your Personal Information, and how you can contact us if you would like to exercise them or if you have any questions or concerns.
This Policy does not apply to Personal Information collected by us offline or through any other means, including on any other website operated by Company or any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site.
We may provide you with a different privacy policy or notice in certain specific situations, in which case that privacy notice or policy will apply to the Personal Information collected or processed in that specific situation, rather than this one.
If you provide us with Personal Information related to anyone other than yourself, please note that you are responsible for complying with all privacy and data protection laws prior to providing that information to the Company (including collecting consent, if required).
Please note that we may collect or process Personal Information as a service provider on behalf of our clients. For example, when you subscribe to receive SMS or text messages from one of our clients, we will collect and process your mobile phone number to deliver these messages on the client's behalf. In those instances, you should consult the client's applicable privacy notice or reach out to the client for information regarding how they process your Personal Information.
The Personal Information We Process and How We Collect It
As used in this Policy "Personal information" means any information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you or your household. Personal Information includes, for example, your name, postal and email addresses, phone number, or bank, debit or credit card information. Under some laws, Personal Information may include your Internet Protocol ("IP") address or other indirect identifiers.
We may process several types of Personal Information about you when you use of our Site, including: (i) Personal Information that you provide to us; (ii) Personal Information we automatically collect through your use of the Site; and (iii) Personal Information we collect from third parties, each as described below.
Personally Identifiable Information that You Provide to Us
In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your Personal Information in connection with your use of our Site.
For instance, you may (i) provide your name, address, and email address to register an account with us or register to learn more; (ii) share your mobile phone number if you wish to receive SMS or text messages from us; (iii) submit contact information (of yourself or your contacts), such as through the use of an advocacy widget; (iv) provide certain demographic information about yourself (e.g., age, gender, purchase preference, usage frequency, etc.) when participating in a survey or poll, or registering or creating a profile through our Site; (v) provide payment information when providing payment via our Site; or (vi) post a general comment and/or recommendation on our Site or if you contact us.
Certain information may not be Personal Information when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity or service, realize a benefit we may offer or gain access to certain content through our Site.
Personal Information We Collect from Third Parties
We may collect Personal Information from third parties, including but not limited to business partners, social networks, data analytics providers, mobile device providers and Internet or mobile service providers.
Personal Information Automatically Collected from You
We may also automatically collect certain Personal Information from you or your device(s) automatically when you access our Site. This information can include, among other things: (i) your IP address or other unique identifiers that are automatically assigned to your computer, mobile or other device used to access the Site; (ii) the domain name of your Internet service provider; (iii) the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, etc.) and/or the operating system you are using (e.g., Windows, Mac OS, etc.); (iv) the third-party website from which your visit originated; (v) the search terms you use on our Site; (vi) the specific areas within our Site that you visit; (vii) the time of day and duration of your visits; (viii) the number of unique views received by the pages of the Site; and (ix) search queries you use on the Site. While not all of the information that we may collect from you is Personal Information when standing alone, it may be associated with Personal Information that we process.
Additionally, certain information regarding your computer systems, network locations, IP address and software may be communicated to us in certain circumstances by the digital rights management systems associated with certain Content that you download or access via the Site in order to prevent unauthorized use or distribution of the associated Content.
Cookies and Other Tracking Technologies
We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Site. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Site, to enhance your experience through personalization, and to help us better understand the features of our Site that you and other users are most interested in.
Website Delivery and Appearance – We may use third-party providers to enable certain customer interaction opportunities, content delivery, or other service capabilities. Examples include, but are not limited to, the following functionality:
- Content Delivery: We partner with service providers to host our Site and deliver specific content in support of our services. For example, we use Google Fonts to serve fonts on our Site, which is governed by Google's Privacy Policy
Cookie Choices – To manage your preferences with respect to these technologies, you can visit our preferences page, or customize your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Site may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
Personal Information Provided as Part of User Content
If you include any of your or another's Personal Information as part of content that you post to the Site ("User Content"), such information may be made available to any parties using the Site and/or such User Content. We do not monitor, edit or otherwise remove such information from User Content before it is posted on the Site. If you do not wish to have such Personal Information made available in this manner, you must not post such information before posting the User Content. Your contact information (which may include, without limitation, your username and email address) may be included with any User Content that you post via the Site. We are not liable for any damages caused or incurred due to Personal Information made available in the foregoing manners.
How We Use Personal Information
We may use your Personal Information:
- To present our Site and its contents to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account/subscription, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Site or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Site.
- To improve the Site, to customize your experience with the Site or to serve you specific content that we believe is relevant to you.
- To secure the Site by detecting, preventing, and responding to security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
- For research regarding the effectiveness of the Site and the business planning, marketing, advertising and sales efforts of Company, its trusted affiliates, independent contractors and business partners.
- In any other way that we may describe when you provide the information.
- For any other purpose with your consent.
We may also use your Personal Information to contact you about our own and third parties' goods and services that may be of interest to you. We may send Company emails that may contain information regarding third-party products or services; however, this does not necessarily mean that we have traded your Personal Information to any party. If you do not want us to use your information in this way, please opt out of further communications as allowed in the email or other message.
Disclosure of Personal Information
We may disclose your Personal Information to our parent, subsidiary, and other related companies, trusted affiliates, independent contractors and business partners who will use the information for the purposes outlined above, as necessary to provide the Site itself and the services offered by the Site, and for the specific purposes for which the information was collected. Note, however, that we will not disclose your mobile phone information to third parties or affiliates for marketing or promotional purposes.
We may also disclose or transfer your Personal Information in connection with or in contemplation of a sale of Company's assets or business or in connection with a merger, consolidation or other reorganization of Company's business.
We may also disclose Personal Information at the request of law enforcement or governmental agencies or in response to subpoenas, court orders or other legal process, to establish, protect or exercise Company's legal or other rights, to defend against a legal claim or as otherwise allowed by law. We may disclose Personal Information in order to protect the rights, property or safety of our users or any other person. We may disclose Personal Information to investigate or prevent a violation of any contractual or other relationship with Company or where we have a good faith belief that access, preservation or disclosure of such information is reasonably necessary to protect the rights, property or safety of Company, its users or the public, or to prevent the perpetration of any illegal or harmful activity.
We may also disclose aggregate, anonymous data based on Personal Information ("Deidentified Information") to content developers, investors, advertisers and potential partners, and as otherwise permitted under applicable law. We will maintain and use Deidentified Information in deidentified form and not attempt to reidentify the information, except that we may attempt to reidentify the information solely for the purpose of determining whether our deidentification processes satisfy applicable requirements.
Security of Personal Information
When you submit Personal Information to us through our Site, you should be aware that your Personal Information is transmitted across the Internet and that no method of transmission over the Internet is completely or 100% secure. While we take reasonable precautions to protect your Personal Information, you also need to ensure you take appropriate steps to protect your Personal Information. We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the Personal Information under our control. Please be advised, however, that while we strive to protect your Personal Information, other information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online, and we are not responsible for the theft, destruction or inadvertent disclosure of your Personal Information or any other information. From time to time, we evaluate new technology for protecting information and, when appropriate, we upgrade our information security systems.
Retention of Personal Information
We will keep your Personal Information only as long as necessary to meet the purposes outlined in the "How We Use Personal Information" section, unless the law requires otherwise. The length of time we retain your Personal Information depends on several factors, such as whether we need it to provide you with requested products or services, maintain our relationship with you, fulfill a legal obligation, follow our recordkeeping policies, or other.
International Use and Cross-Border Data Transfers
If you are visiting our Site from outside of the United States, please note that our Site is hosted in the United States. Where permitted by applicable law, we may transfer the Personal Information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Policy.
Children Under the Age of 13
Although our Site is a general audience website, it is not intended for children under 13 years of age, and we restrict the use of our service to individuals aged 18 and above. No one under age 13 may provide any information to or on the Site, and we do not knowingly collect Personal Information from children under 13. If we learn we have collected or received Personal Information from a child under the age of 13 without verification of parental consent, we will delete that information.
Your Rights
Depending on where you live, you may have the following rights with respect to your Personal Information:
- Access: You may have the right to know what Personal Information we have collected about you and to access such data.
- Data Portability: You may have the right to receive a copy of your Personal Information in a portable and readily usable format.
- Deletion: You may have the right to delete your Personal Information that we have obtained, subject to certain exceptions.
- Correction: You may have the right to correct inaccuracies in your Personal Information.
- Restriction of processing: You may have the right to request that we restrict certain processing of your Personal Information.
- Withdrawal of consent: Where we process your Personal Information only with your consent, you may have the right to withdraw previously given consent. Processing of Personal Information based on consent before the withdrawal remains lawful.
We do not (1) sell your Personal Information; (2) disclose your Personal Information to third parties for targeted or cross-context behavioral advertising; (3) use Personal Information for profiling or automated decision-making; or (4) use sensitive Personal Information outside of purposes permitted by law. We do not, therefore, recognize requests to opt out of these uses of Personal Information.
You may also have the right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you register an official complaint.
Exercising your rights
To the extent applicable, you can review and change your Personal Information by logging into the Site and visiting your account profile page.
Additionally, to exercise any of the privacy rights afforded to you under applicable data protection law, you may submit a request to us by emailing us at [email protected] or calling us at 202-704-5452.
To opt out of marketing emails, you can use the unsubscribe link found in the email communication you retrieve from us. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.
If you receive SMS or text messages from us, you can follow the instructions in those messages to stop receiving such messages in the future.
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Policy. However, should you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some, or all, of our services to you.
We endeavor to respond to requests within the time period required by applicable law. If you are not satisfied with the resolution of your request, please let us know.
Only you, or an authorized agent may make a request related to your Personal Information. You may also make a request on behalf of your minor child.
Except where data protection laws provide otherwise, you may only make a request for access or data portability twice within a 12-month period.
Verification
We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor's identity. If you are an authorized agent making a request on behalf of a consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.
We do not charge a fee to process or respond to your 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.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.
We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.
Please note: If you delete your User Content from the Site, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access and use of information provided on the Site, including User Content, is governed by our Terms of Service.
California Residents
In accordance with the California Consumer Privacy Act ("CCPA"), we collected the following categories of Personal Information within the preceding 12 months:
- Identifiers such as your name, alias, email address, or mailing address;
- Internet or other electronic network activity information, including information on your usage of our Site;
- Commercial information, including records of products or services purchased or other purchasing histories;
- Categories of Personal Information as defined by Cal. Civ. Code § 1798.80 (for example, name, signature, telephone number);
- Inferences drawn from any information identified above to create a profile.
For each category of Personal Information set forth above, the categories of third parties to whom we disclose it for a business or commercial purpose are set forth in the "Disclosure of Personal Information" section above. In the past 12 months we did not "sell" or "share" (as those terms are defined under the CCPA) your Personal Information.
California Shine the Light
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Information about you by the Company to third parties for the third parties' direct marketing purposes. To make such a request, please send an email to [email protected].
Changes to our Privacy Policy
We reserve the right to change, modify, add or remove all or portions of this Policy from time-to-time in our sole discretion. All changes are effective immediately when Company posts them and apply to all access to and use of the Site thereafter. You are expected to check this page each time you access the Site, so you are aware of any changes, as they are binding on you. We may (and if required by law will) also provide notification of change in another way that we believe is reasonably likely to reach you, such as via email (if we have your contact information) or another manner through the Site.
Notices
All feedback, inquiries, comments, notices, and other communications relating to this Privacy Policy should be directed to:
PolicyEngage, LLC
1 Thomas Cir NW, Suite 700
Washington, DC 20005
202-704-5452
Email: [email protected]