Privacy Policy

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, including Opt-In Text Message Services (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 applies to any third-party service providers, agents, or affiliates of Groundswell, defined as trusted partners or vendors who collect data on our behalf (e.g., analytics providers or payment processors), and legal or financial advisors in the context of compliance checks, audits, or legal claims. Our Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Services. 

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   

Groundswell collects only data that is necessary for specific purposes, ensures that data is kept accurate, up-to-date, and relevant, and avoids collecting sensitive Personal Identifiable Information (PII) unless legally required or explicitly consented to.

Personal Identifiable Information and usage information   

“Personal Identifiable Information” means information the Company has collected or otherwise maintains or has in its possession that identifies or can be used to identify or authenticate an individual, including, but not limited to: 

  • Names
  • Addresses
  • Telephone numbers.
  • Email addresses.
  • Employee identification numbers.
  • Government-issued identification numbers.
  • User passwords or PINs.
  • User identification and account access credentials, passwords, PINs and security question answers.
  • Financial account numbers.
  • Geolocation data.
  • Biometric, medical, health, or health insurance information.
  • Utility records.
  • Personal characteristics or profiles connected to a unique individual, including interests, habits, or activities.

“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. 

Third-Party Access and Legal Disclosures

All third parties must comply with our Data Processing Agreement (DPA), follow our security and retention policies and allow audits and compliance checks, if required. Mobile opt-in data and information will not be shared with third parties/affiliates for marketing/promotional purposes. Phone numbers will not be shared with third parties, unless required by law.

We may share data with:

External subrecipients and contractors

  • Under completed and signed NDAs, adopted data privacy policy, and data processing agreements

Legal, financial, regulatory and compliance officials

  • For audits, litigation, or regulatory purposes

Third-party vendors

  • Cloud services, analytics tools) with strong data protection standards

“Personal Identifiable Information” may only be shared with subrecipients, partners, contractors, agents, affiliates, and/or representatives (“Third Party Service Provider”) if it has a need to know the information for the purpose of providing the contracted services and if sharing the PII complies with the privacy notice provided to the Data Subject. Groundswell personnel will not share PII with a Third-Party Service Provider without prior written supervisor approval and a fully executed written contract.

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.