Website Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By accessing and using the Site, you agree to be bound by the terms and conditions of this Privacy Policy.

This Privacy Policy governs the manner in which PolicyEngage, LLC ("we", "us", "our" or "Company"), collects, uses, maintains and discloses information collected from you ("you" or "your") and other users (collectively, "Users") through your interaction with Company, including your use of any Company-operated website that links to this Privacy Policy and other products or services that are offered or provided by us (collectively, the "Site").

This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Company or any third party, or any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site.

This Privacy Policy will notify you of the following:

1. What personally identifiable information is collected from you through the Site, how it is used and with whom it may be shared.
2. What choices are available to you regarding the use of your data.
3. The security procedures in place to protect against the misuse of your information.
4. How you can correct any inaccuracies in the information.

We keep this Privacy Policy posted on our website, available at https://policyengage.com/privacy, and you should review it frequently, as it may change from time to time in our sole discretion and without notice to you. Any changes will be effective immediately upon the posting of the revised privacy policy.

The Information We Collect and How We Collect It

Information That We Collect

We collect several types of information from and about you and other Users of our Site, including: (i) personally identifiable information that you provide to us; and (ii) information we automatically collect through your use of the Site, both as described below.

Personally Identifiable Information that You Provide to Us

Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, postal and email addresses, phone number or bank, debit or credit card information. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your personally identifiable 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) submit contact information (of yourself or your contacts), such as through the use of an advocacy widget; (iii) 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; or (iv) provide payment information when providing payment via our Site; or (v) post a general comment and/or recommendation on our Site or if you contact us.

Certain information may not be personally identifiable 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.

Information Automatically Collected from You

We also automatically collect certain information from you 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., Vista, Windows XP, 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 collect from Users is personally identifiable, it may be associated with personally identifiable information that Users also provide to us.

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.

How We Collect This Information

We collect this information directly from you when you provide it to us, when you post on the Site, and automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies (as defined below).

Cookies

Like most web sites, the Site uses web logs and browser cookies, which is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site. Another type of cookie, called a "session" cookie, is used to identify a particular visit to the Site. Session cookies expire after a short time or when you close your web browser. You can choose to disable cookies on your browser or allow your browser to notify you when a cookie is being sent, however this may prevent you from utilizing certain features of the Site. Finally, certain features of our Site may use local stored objects (or "Flash" cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.

IP Addresses

Due to the communications standards on the Internet, we automatically receive the uniform resource locator (URL) of the web site from which you came and the web site to which you proceed once you leave the Site. We also receive the IP address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, as well as the name of your Internet service provider (ISP). This information is used to analyze overall trends to help us improve the Site. The linkage between your IP address and your personally identifiable information is shared with third parties in accordance with this Privacy Policy.

Web Beacons and Ad Networks

Pages of our the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We may also allow other companies, called ad networks, to serve advertisements to Users via the Site. Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. We may "target" some ads to Users that fit a certain general profile. To deliver these ads properly, the Site may include a file, called a web beacon, from these ad networks within pages served by the Site or implement other monitoring technologies so the networks may provide anonymous, aggregated auditing, research and reporting for advertisers as well as to target ads to you while you visit other web sites. These general targets may also be used by ad networks to display targeted ads on other web sites as a substitute for random, irrelevant ads. In addition, the Site may use the technology of ad networks to serve ads only when you visit this Site. Ad networks may use non-personal information, such as your state or zip code, in order to provide advertisements about goods and services that may be of particular interest to you while you visit this Site. Because your web browser must request these advertisements and web beacons from the ad network's servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.

Personal Information Provided as Part of User Content

If you include any of your or another's personally identifiable information as part of the User Content that you post to the Site, 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 personally identifiable information made available in this manner, you must not post or otherwise remove 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 personally identifiable information made available in the foregoing manners.

How We Use Information

We use information that we collect about you or that you provide to us, including any 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.
• 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 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. To opt out of further communications from a marketing partner or sponsor with whom your information has been shared, please contact that partner directly.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Information

We may disclose personally identifiable information collected from you and other Users 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. We may also disclose or transfer personally identifiable information and non-personal information collected from Users 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 personally identifiable 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 personally identifiable information in order to protect the rights, property or safety of a User or any other person. We may disclose personally identifiable information to investigate or prevent a violation by a User 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 information collected from Users to content developers, investors, advertisers and potential partners.

Security of Information

When you submit information to us through our Site, you should be aware that your 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 information, you also need to ensure you take appropriate steps to protect your information. We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control. Please be advised, however, that while we strive to protect your personally identifiable 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 personally identifiable information or any other information. In the unfortunate event that your "personally identifiable information" (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion), to the last e-mail address you have provided us, in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time, we evaluate new technology for protecting information and, when appropriate, we upgrade our information security systems.

Consent to Worldwide Transfer and Processing of Personal Information

By providing us with personal information, you acknowledge and agree that your personal information may be transferred outside of the country from which you are accessing the Site, including transferred outside the European Economic Area ("EEA"), to the United States. Each of these countries has different privacy laws that afford varying levels of protection for your personally identifiable information, and such laws may not be as comprehensive as those that exist in the EEA. By registering on the Site or otherwise using our Site and services, you consent to our and our affiliates’ transmission to, and collection and processing of your information in, any jurisdiction, in accordance with this Privacy 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 age 18 and above. No one under age 13may 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.

California Residents

The state of California provides its residents with certain rights concerning their Personal Information (as defined by the California Consumer Privacy Act). This section describes how you may exercise your rights for Personal Information that we collect through the Site and offline.

A. Categories of Personal Information Subject to California Privacy Rights

In accordance with California law, we collected (through the Site and offline) 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.

We share each of these categories of Personal Information with our service providers to the extent necessary to provide their services and as otherwise described, above.

B. Your California Privacy Rights

In accordance with California law, California consumers may exercise the following rights with respect to their Personal Information:

Privacy Right	Description
Access	You have the right to request information on the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You also have the right to request information on the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Data Portability	You have the right to receive the Personal Information you have previously provided to us.
Erasure	You have a right to request us to delete Personal Information that we collected from you. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law; (4) to otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt-Out	You have a right to opt-out of certain disclosures of Personal Information to third parties, if such disclosures constitute a "sale" under California law. As noted above, we enable advertisers to collect certain information from the Site, which the advertisers may use to improve their interest-based advertising networks. Regardless of whether this is a "sale," you may opt-out of interest-based advertising by visiting the Network Advertising Initiative’s Opt-out page.

If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to [email protected]. You have a right not to receive discriminatory treatment by any business when you exercise any of your California privacy rights.

While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:

• Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the Personal Information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf;
• Help Us Verify Your Identity: Provide us with information to verify your identify. For example, provide us (at a minimum) your phone number or email address. If your phone number or email address appears in our records, we may contact you to help confirm that you are making the request. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
• Direct Our Response Delivery: Please provide us with an e-mail or mailing address through which we can provide our response. If make the request by email, unless otherwise requested, we will assume that we can respond to the email address from which you made the request.

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Data 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].

Correcting, Updating, Accessing or Removing Personal Information

To the extent applicable, you can review and change your personal information by logging into the Site and visiting your account profile page.

We will endeavor to provide a way to correct, update and/or remove your previously-provided personal information. This can be done by emailing a request to Company at [email protected]. Please note that in certain circumstances, we may not be able to completely remove your information from its systems. For example, we may retain your personal information for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, for account recovery purposes, if required by law or as retained in Company's data backup systems or cached or archived pages. All retained personally identifiable information will continue to be subject to the terms of the Privacy Policy.

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.

Opt-Out

When you sign up for our updates or to receive e-mail or other messages from us, you will always be given the chance to opt-out of emails, special offers, updates, and other messages. You may change your preferences at any time and will only be contacted in manners consistent with your stated preferences.

Please understand that even if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.

Changes to our Privacy Policy

We reserve the right to change, modify, add or remove all or portions of this Privacy Policy from time-to-time in its sole discretion. All changes are effective immediately when Company posts them, and apply to all access to and use of the Site thereafter. Your continued use of the Site following the posting of revised Privacy Policy means that you accept and agree to the changes. 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.

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]