Updated December 2019
Your privacy is important to us
Other than as direct customers, there are two ways in which you might interact with DDC. The first way is by visiting our site. The second is by receiving email from us as part of our services to our customers—that is, we send emails to individuals (employees, members, business partners, etc.) from lists provided to us by our customers.
COLLECTION AND USE OF INFORMATION
We may collect certain non-personally identifiable information when you visit our Site, such as the type of browser you are using (e.g., Chrome, Safari), the type of operating system you are using, (e.g., Microsoft Windows), and the domain name of your Internet service provider (e.g., Verizon, Comcast). We sometimes use the non-personally identifiable information that we collect to improve the design and content of our Site as well as our services.
For users of our products and services, DDC offers users the option to provide us certain personal information. This information may be required in order to receive certain services from us. By providing us with such information, you are agreeing that we may store, process, and review such information and that we may use it for the purpose for which it was collected. For example, we may use this information to enable you to communicate with you legislators or to personalize your user sessions. We may also use email and street addresses voluntarily provided by site visitors to notify them of updates, products, services, or upcoming events. Site visitors who do not wish to receive such notifications via email can choose to opt out of receiving such information at any time by so indicating either at the time of registration or upon receipt of any promotional email.
You may also receive emails from our service, which have been sent by an employer, business partner, or other entity with which you have a relationship (such as a non-profit organization). Communications sent through DDC’s servers are at the expressed direction and use of our clients and their constituents. Our service allows our customers to send out emails to their members, employees, business partners, etc., advising them of news and important developments, requesting that they take certain action, requesting that they contact their political representatives, and the like. It is our policy that such emails contain an “unsubscribe” function, along with instructions on how to do so.
Please understand that we may have received your email address from our customer. As stated above, we will not disclose it to others, but understand that it may have been disclosed to us from someone other than you. Presumably, that individual or entity has a relationship with you; however, if not, you have the option of unsubscribing.
Lastly, we may use aggregated, non-personally identifiable information in order to gauge the effectiveness of certain grassroots activities. We use this information in our consulting business but please be assured that there is no personally identifiable information of yours disclosed as part of our use of this aggregated information.
DDC websites may contain links to other sites. Please be aware that DDC is not responsible for the privacy practices of other sites. We encourage users, when they leave a site, to read the privacy statements of each website that collects personally identifiable information. If you have any questions or concerns regarding what we do with information provided to us, please contact us.
OUR COMMITMENT TO SECURITY
We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect.
DDC provides data and website services to some of the country’s largest companies and associations. DDC’s physical security, network security, and data integrity procedures are continually evaluated by our clients and third parties to ensure that our systems and procedures meet the high standards required by our clients.
DDC has a robust, multi-layered network infrastructure and monitors its entire network around the clock to identify any perceived threats and monitor the performance of our products to ensure that our entire infrastructure remains highly available and secure.
PASSWORDS AND OTHER IDENTIFIERS
In the event you are issued a password or other secret identification in order to receive a service from us you must not disclose or share your password with any third party. If you lose control of your password, you may lose control over the information you have provided to us, and you will be responsible for any legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password, or, if we provided your password, notify us so that we may issue you a new password.
California Consumer Privacy Statement
This California Consumer Privacy Statement supplements this Policy and applies solely to California consumers. This section provides information about our online and offline privacy practices. This Statement does not apply to our personnel.
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you.
- Identifiers:identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80:such as signature, physical characteristics or description, education, financial information
- Protected Classifications:characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
- Commercial Information:commercial information, such as records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity:Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Geolocation Data
- Sensory Information:audio, electronic, visual, and similar information
- Employment Information:professional or employment-related information
- Education Information:education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
- Inferences:inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
We may use the categories of personal information listed above for the purposes described in this Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:
|Purposes||Categories of Personal Information|
|Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services||Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences|
|Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance||Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences|
|Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction||Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences|
|Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity||Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences|
|Debugging to identify and repair errors that impair existing intended functionality||Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Geolocation Data; Employment Information; Education Information and Inferences|
|Undertaking internal research for technological development and demonstration||Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences|
|Undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance the service|
In addition, we may also use the following categories of personal information for purposes of managing our career opportunities: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Sensory Information; Employment Information; Education Information and Inferences
Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that time-frame, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.
- Sources of Personal Information
We may have obtained personal information about you from various sources, as described below:
|Categories of Sources of Data Collection||Categories of Personal Information|
|Directly from you, such as when you contact us with a question or comment||Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences|
|From your devices, such as when you visit our Site|
|Our Clients||Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences|
|Our affiliates and subsidiaries|
|Vendors who provide services on our behalf|
|Online advertising companies|
|Consumer data resellers|
- Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below:
|Categories of Third Parties||Categories of Personal Information|
|Our affiliates and subsidiaries|
|Vendors who provide services on our behalf|
|Professional services organizations, such as auditors and law firms|
|Our joint marketing partners|
|Our business partners|
|Internet service providers|
|Data analytics providers|
|Operating systems and platforms|
- Sale of Personal Information
We have previously and will collected information about you for the purpose of providing it to our clients in situations described above under COLLECTION AND USE OF INFORMATION. These situations include, for example, when we collect information about individuals for market research and focus groups; promotions; surveys and voting; media monitoring; and industry information. These services are provided at our clients’ request for monetary consideration. This may be considered the sale of personal information for purposes of the CCPA.
We may sell your personal information in connection with the sale of DDC Public Affairs or the division or office responsible for the services.
You have the right to opt out of this disclosure of your information, as detailed below. During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may be considered to have sold the following categories of personal information for the purposes described above: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences.
We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.
- Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties the following categories of personal information for a business purpose: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; Education Information and Inferences.
California Consumer Privacy Rights
You have certain choices regarding our use and disclosure of your personal information, as described below.
Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.
How to Submit a Request: How to Submit a Request: To submit an access or deletion request, to submit a Shine the Light request or to opt-out of the sale of your personal information, email firstname.lastname@example.org.
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide us with information about you to verify your identity. The type of information that we ask for may vary depending on the type and sensitivity of the personal information we hold about you or that you request. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact email@example.com to request this Statement in an alternative format.