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Privacy Policy

Effective Date: August 04, 2019

This Privacy Policy describes how we, Groundswell, Inc., collect, use, disclose and store information you provide to us. The Privacy Policy applies to www.groundswell.org (the “Site”) and any application, service or tool available through or posted on the Site (collectively with the Site, the “Services”). The Services are operated by or on behalf of Groundswell, Inc., 80 M Street SE, Washington, DC 20003.

This Privacy Policy describes:

  • Information that we receive from you when you interact with the Services
  • How we use and process the information that we receive
  • If and why Personal Information may be disclosed to third parties
  • Your choices regarding the collection and processing of your Personal Information

Our Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Services, or to information that you submit to us through email or other electronic messaging, or offline.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you submit information to or through the Services, or otherwise use the Services, you consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy.  This Privacy Policy is incorporated into and made a part of our Terms of Use. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

The Effective Date of this Privacy Policy is set forth at the top of this webpage. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

 

Information We Collect   

Personal information and usage information   

“Personal Information” means information associated with or used to identify or contact a specific person. Personal Information includes: (1) contact data (such as mailing address, service address, e-mail address, telephone number and employer); (2) demographic data (such as gender, date of birth and zip code); (3) certain Usage Data (defined below), such as IP address; (4) social security number, Pepco account number, electricity consumption data and payment account information; and, when relevant, (5) income-qualifying information.

“Usage Information” or “Usage Data” is information about an individual's online activity that, by itself, does not identify the individual, such as browser type, operating system and webpages visited. Generally, we do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual. Personal Information and Usage Data may be linked together. Different types of Usage Information also may be linked together and, once linked, may identify an individual person. Also, some Usage Data may be Personal Information under applicable law.

Other possible categories of Usage Data are:

  • technical information, such as the user's mobile service provider, the web browser or other applications or programs through which the user used to accessed the Services, the user's IP address and the user's device's version and identification number;
  • information about what the user have searched for and looked at while using the Services, such as web search terms used, social media profiles visited and details of other information and content accessed or requested in using the Services;
  • information about communications the user made using the Services, such as the people the user communicated with and the time, data and duration of the user's communications; and
  • metadata, which means information related to items the user made available through the Services, such as the date, time or location that a shared photograph or video was taken or posted.
Sensitive personal information   

Certain Personal Information, such as information about personal health or finances, is characterized as sensitive and subject to stricter regulation than other personal information. Before providing it, we urge you to carefully consider whether to disclose your sensitive Personal Information to us. If you do provide sensitive Personal Information to us, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Policy. Information relating to payment card information is treated under the PCI-DSS standards.

Location data

“Location Data” is a category of Personal Information collected about the location of a mobile device or computer, including:

  • the location of the mobile device or computer used to access the Services derived from GPS or WiFi use;
  • the IP address of the mobile device or computer or internet service used to access the Services,
  • other information made available by a user or others that indicates the current or prior location of the user, such as information that you or others post indicating your location.
Combining information from third party sources

We may combine the information we collect from you with information from other sources and use the combined information as described in this Privacy Policy.

 

How Information Is Collected    

Information Collection In General

We collect information that you provide to us and from your use of the Services. The information that we collect and how we process it depends on how you use and access the Services. Some information is collected automatically through use of cookies and similar data collection tools. To learn more about how and why we use cookies and similar tools to collect information, please see “Cookies And Other Information Collection Tools” below.

From You

We collect information from you:

  • We collect Personal Information and Usage Data from you when you create an account to use any of the Services, contact us for help or information or otherwise voluntarily provide your Personal Information.  We also collect Personal Information and Usage Data from you when you engage in transactions through our Services. 
  • The Services may offer you the ability to use Facebook Connect or other social media services (collectively, “Social Media”) in conjunction with certain Services. When you access the Services through your Facebook or other Social Media account, the Services may, depending on your privacy settings, have access to information that you have provided to the Social Media platform. We may use this information for the purposes described in this Privacy Policy or at the time the information was collected.
  • Third parties that assist us with our business operations also collect information (including Personal Information and Usage Data) about you through the Services and share it with us. For example, our vendors collect and share information with us to help us process payments, or to detect and prevent fraud.
  • We also automatically collect Usage Data when you interact with the Services, including your search queries and when you respond to market research surveys. 
Cookies And Other Information Collection Tools    

Cookies

We and the service providers that help us provide the Services use small text files called cookies. “Cookies” are small computer files sent to or accessed from your web browser or your computer's or tablet's hard drive that contain information about your computer, such as a user ID, user settings, browsing history and activities conducted while using the Services. Cookies are not themselves personally identifiable but may be linked to Personal Information that you provide to us through your interaction with the Services. A Cookie typically contains the name of the domain (internet location) from which the Cookie originated, the “lifetime” of the Cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.

Cookies help us improve the Services by tracking users' navigation habits and storing users' password, customizing users' experience with the Services; enabling us to analyze technical and navigational information about the Services; and helping to detect and prevent fraud.

We also use other Cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “Data Collection Tools,” to help improve your experience with the Services. For example, Data Collection Tools help us remember users and make the Services more relevant to them.

The Services also may use Data Collection Tools to collect information from the device used to access the Services, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer or device is located.

Web browsers allow some control of most Cookies through the browser settings. To find out more about Cookies, including how to manage and delete Cookies, visit www.allaboutcookies.org. Some web browsers (including some mobile web browsers) provide settings that allow a user to reject Cookies or to alert a user when a Cookie is placed on the user's computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept Cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Services.  We may also use Cookies through Google Analytics.  For more information on collection and processing of data through Google Analytics, please see www.google.com/policies/privacy/partners. 

Third Party Tracking    

Our advertising management partners use Data Collection Tools through the Services to enable them to recognize a unique Cookie that has been placed on a user's browser, which in turn enables us and these ad management partners to learn which advertisements bring users to the Services. In addition, we and our ad management partners may use these Data Collection Tools to track the actions of users of the Services, to measure statistics of our marketing efforts, and to deliver advertisements on the Services that may be more relevant to you.

We and our ad management partners also may use Data Collection Tools to record the actions of users of the Services, to measure statistics of our marketing efforts, to deliver advertisements on the Services that may be more relevant to individual consumers and to improve the consumer experience on the Services.

We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance. This means that we allow users to exercise choice regarding the collection of information about their online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at http://www.aboutads.info/principles/.

Opting Out of Interest-Based Advertisements

Users may “opt out” of receiving online interest-based advertisements by following the instructions at www.aboutads.info/choices or www.networkadvertising.org/choices/.  After opting out, an “opt-out” Cookie will be placed on the user's device indicating that the user does not want to receive interest-based advertisements. If a user deletes Cookies generally, the user will need to opt-out again.

Opting out of interest-based advertising does not mean users will no longer see advertisements from us or on the Services; rather, opting out means that the online ads presented will not be based on the user's particular interests.

In addition, even after opting out of receiving interest-based advertisements, Data Collection Tools on the Services may collect information about users' activities on the Services, including for analytics, fraud prevention and any other purpose permitted under the Principles.

Data Collection by Third Parties

Certain third parties that we do not control may use Data Collection Tools on the Services. This Privacy Policy does not apply to those third parties or their Data Collection Tools.

 

How Information Is Used    

We use the Personal Information that we collect to operate the Services, to provide customer service, customize our advertising and marketing, to detect, and to prevent and mitigate fraudulent or illegal activities. You agree that we may use your Personal Information to:

  • Operate, improve and personalize the Services, including to
    • Provide you with the use of and access to the Services
    • Customize, measure and improve the Services
    • Provide content that we think users will like
    • Provide products and services requested by you
    • As described when we collect the information or to fulfill any other purpose for which you provide it
  • Provide customer service and support for the Services or for the products and services offered through the Services, including to
    • Contact users, either via email or telephone (using autodialed or pre-recorded calls), text (SMS) messages (if applicable) as authorized by the recipient user, to resolve disputes, collect fees and troubleshoot problems with the Services and for other purposes authorized by law and consistent with this Privacy Policy (message and data rates may apply)
    • Check and verify Personal Information with third parties as necessary
    • Customize our advertising and marketing communications
    • Customize, measure, and improve our content and advertising based on users' ad customization preferences
    • Contact users, either via email, telephone, text (SMS) messages (if applicable based on your consent; message and data rates may apply), postal mail, or otherwise as authorized by you to inform you about the Services, special offers, etc.
  • Detect, prevent and mitigate fraudulent or illegal activities
    • Prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities
    • Enforce our Terms of Use or other applicable policies

 

Sharing And Disclosure Of Information   

We may share and disclose information as described at the time information is collected or as follows:

To Perform Services

We may disclose Personal Information to third parties in order to perform services requested or functions initiated by users. In addition, we may disclose Personal Information in order to identify a user in connection with communications sent through the Services. We also may offer users the opportunity to share information with friends and other users through the Services.

With Third Party Service Providers Performing Services For Us Or On Our Behalf

We share information, including Personal Information, with our service providers to perform the functions for which we engage them (such as hosting and data analyses). We may share information as needed to operate other related services.

For Legal Purposes

We may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to comply with applicable laws and law enforcement agencies, and to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.

Corporate Changes

We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated entity (in each case whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before your information is transferred or becomes subject to a different privacy policy.

Choices About Use And Disclosure Of Information   

Personal account information can be updated and managed either online at www.groundswell.org or by contacting Customer Service at [email protected] .

 

How Information Is Retained And Secured   

We retain information as long as it is necessary and relevant for our operations. In addition, we retain personal information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use, collect any fees owed and other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion policies.

We employ industry standard security measures designed to protect the security of information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

Linked Sites And Services    

The Services may contain links to third-party websites and services (“Third Party Services”) with which we have no affiliation. A link to any Third Party Service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third Party Service, you are subject to its privacy policy and practices (and its other terms and conditions) and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

Children    

The Services are not intended for use by children. If you are under the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services and subsequently we will delete that information.

Do Not Track 

How We Respond to Browser “Do Not Track” Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to digital services that a visitor does not want to have his/her online activity tracked. If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block that digital service from collecting certain Personal Information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, we and many other digital service operators do not respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.

User-Generated Content 

The Services may offer users the opportunity to submit or publish or share comments and other content (“User Content”). Personal Information in User Content may be made available to others and may be used in unexpected ways. You submit your User Content at your own risk. We may access and use your User Content consistent with this Privacy Policy.  User Content is not moderated and may be modified or deleted (in whole or in part) for technical or other reasons.

To request removal of User Content, please contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information.  California’s “shine the light” law (Civil Code §1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  To make such a request, please send an email to: [email protected].

EU Personal Information Processing 

Any personal information collected about EU visitors through the Services is processed in the United States or in other countries in which we or our affiliates, subsidiaries or service providers host these Services. When you provide personal information to us through the Services, you consent to the processing of your data in, and the transfer of your data to, the United States or any other country in which we or our affiliates, subsidiaries or service providers host these Services.