Last Updated February 15, 2021
To ensure you are fully informed of our practices, we recommend that you read the entire Policy. However, to make it easier for you to review the parts of this Policy that apply to you, we have divided up the document into sections that are specifically applicable to Clients, Contacts, and Visitors. The remaining information is applicable to everyone.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the end of the Policy.
Ecclesia provides nonprofit and political candidates, campaigns, and caucuses the ability to effectively manage their contact database, conduct meaningful outreach activities, and provides the support system necessary to run an effective campaign in the 21st century.
Solely for the purposes of this policy, "personal information" means any information that identifies or can be used to identify an individual directly or indirectly (e.g., first and last name, date of birth, email address, gender, occupation, or other demographic information) and "you" and "your" means, depending on the context, either a Customer, a Contact, or a Visitor.
Information We Collect
The personal information that we collect depends on the context of your interactions with Ecclesia, the Ecclesia products and their respective features you use, your location, and applicable law.
You (or your organization) may provide certain personal information to us when you sign up for an and use the Ecclesia products, consult with our customer service team, send us an email, integrate a program with another service, or communicate with us in any other way. This information may include:
- Business contact information (such as your name, job title, organization, location, phone number, email address, and country).
- Marketing information (such as your contact preferences).
- Account log-in credentials such as your email address or username when you sign up for an account with us.
- Troubleshooting and support data (which is data you provide or we otherwise collect in connection with support queries we receive from you, including contact or authentication data, the content of your communications with us, and the product or service you are using related to your help inquiry).
How we use Personal Information
The following list is general description of how we use your information:
- To facilitate, operate, and provide our Services;
- To associate your Hubble account with a voter profile;
- To connect you with other like-minded Democratic candidates and organizations;
- To provide you with news and information about Ecclesia, Hubble, and our associated campaigns as well as information about upcoming campaign events or activities in your area;
- To contact you for other purposes or to solicit you for contributions;
- To comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
We may sell, share, or generally allow your personal information to be used by our clients in order to provide a better political campaign. Below are the different scenarios under which we may sell, share, or generally your data with third parties.
Service Providers. With our contracted service providers, who provide services such as IT and system administration and hosting, research and analytics, marketing, legal, accounting, banking, auditing, insuring us, customer support and data enrichment for the purposes and pursuant to the legal bases described above; such service providers comprise companies located in the countries in which we operate.
Compliance with Legal Obligations. We may disclose your personal information to a third party if (i) we reasonably believe that disclosure is compelled by applicable law, regulation, legal process, or a government request (including to meet national security, emergency services, or law enforcement requirements), (ii) to enforce our agreements and policies, (iii) to protect the security or integrity of our services and products, (iv) to protect ourselves, our other customers, or the public from harm or illegal activities, or (v) to respond to an emergency which we believe in good faith requires us to disclose data to assist in preventing a death or serious bodily injury.
If Ecclesia is required by law to disclose any personal information, we will make commercially reasonable efforts to notify you of the disclosure requirement, unless prohibited by law. Further, we may object to requests we do not believe were issued properly.
Business transfers. If we go through a corporate sale, merger, reorganization, dissolution or similar event, data we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction. In that situation, and that situation only, we might transfer your data in a way that constitutes a sale under applicable law. If we do, we will let you know ahead of time, and any acquirer or successor of Ecclesia may continue to process data consistent with this notice.
Cookies and Tracking Technologies
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another Consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code ¬ß 1546et. seq.).
- Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- We do not provide these deletion rights for B2B personal information.
- Ecclesia does "sell" personal information to third parties as that term is defined in the CCPA.
Exercising Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us by using the contact information in the Contact Us section of this Policy. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may only make a request for access or data portability twice within a 12-month period. The request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may vary based on the nature of your request.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
- Making a verifiable Consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
- We will only use personal information provided in a verifiable Consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable Consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically a .csv file. We do not charge a fee to process or respond to your verifiable Consumer 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.
Information from Children
We do not knowingly collect the information of children (under the age of 13). If we discover someone who is underage has signed up for access to the Ecclesia programs or their data has entered into the database, we will take reasonable steps to promptly remove that person's personal information from our records. If you believe a person who is underage has signed up for access to the Ecclesia programs or has been added to the database, please contact us at firstname.lastname@example.org
Do Not Track ("DNT") is a privacy preference that you can set in most web browsers. Certain state laws require us to indicate whether we honor DNT settings in your browser. Ecclesia currently supports DNT; however, there is no accepted standard on how to respond to web browsers' DNT signals and even when you have DNT enabled, we may still use information collected for analytics and measurement purposes or to otherwise provided to the Ecclesia programs but we will not load any third-party trackers.
Changes to our Privacy Notice
To exercise your rights regarding your personal information, or if you have any questions regarding this Policy or our privacy practices please email us at email@example.com or write to us at:Ecclesia, LLC
ATTN: Director, Data Operations
PO Box 966
Worthington, OH 43085
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.