Last Updated: September 14, 2017
Welcome to the Privacy Policy (the “Policy”) of The Advocator Ventures, LLC (the “Company”, “The Advocator”, “we”, “our” and/or “us”). The Advocator offers an online crowdfunding platform for people and entities seeking to raise funds for their own coalitions and to contribute to the coalitions of others. In this Policy we refer to those raising funds as “Coalition Leaders” and to their fundraising campaigns as “Coalitions.” We refer to those contributing funds as “Contributors” and to the funds they contribute as “Contributions.” Coalition Leaders, Contributors and others accessing or using the Services (defined below) are referred to collectively as “Users.” We value the privacy of our Users and want to help you make informed decisions about your relationship with us, so please review it carefully.
This Policy, effective on September 14, 2017, is part of our Terms of Service and applies to personally identifiable and non-personal information (collectively, the “Information”) we collect from you and how we use that information. Each time you access, use, register with, or browse The Advocator website, applications content or services (collectively, the “Services”), you expressly consent to The Advocator’s then-current Privacy Policy, and the policies and practices described therein.
I. Information You Provide
In order to use The Advocator Services, subscribe to our newsletters, contribute funds, or request any information, we need to collect and process certain information about you. When registering an account with The Advocator Services (the “Account”), you may be asked to enter your name, email address, mobile phone number, or other similar details. You may also choose to voluntarily add other information to your profile, such as your mobile service provider, gender, date of birth, address, postal code, and country.
If you connect to the Services using credentials from a Third Party Application (as defined in the Terms of Service) (e.g., Facebook, LinkedIn), you authorize us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available on or through your Third Party Application account, including, for example, your name, profile picture, country, hometown, email address, date of birth, gender, friends’ names and profile pictures, and networks.
Upon Account registration, The Advocator will ask you to allow it to have access to and import your contacts stored in your mobile or relevant device (the “Contacts”). If you agree, Advocator will import the information of all of the Contacts. By agreeing to allow The Advocator to have access to and to import your Contacts, you are agreeing to share any and all contact information in your Contacts with The Advocator. The Advocator may utilize this information in order to reach out to your Contacts and invite them to join The Advocator. By allowing The Advocator access to your Contacts, you agree that The Advocator may reach out to your Contacts and invite them to join The Advocator. You agree that by sharing your Contacts, you are legally authorized to share such information. You agree to hold The Advocator harmless and indemnify us from any damages, including attorneys’ fees and court costs, resulting from your unauthorized sharing of information.
You control who can see your Contributions. You have the option to make your Contributions private. If you choose to keep your Contributions public, you agree that they shall be public and accessible by anyone utilizing The Advocator.
II. Information We Collect
We may collect and store the following information:
A. Content and Information About You
We may collect personally identifiable information from you including, without limitation, non-public information about you that helps The Advocator identify you, such as first and last name, birth date, business title, employer, email address, employer or personal address, telephone number, gender, account username and password, information regarding Coalitions that you contribute to, information you provide to us when you contribute to a Coalition (e.g., shipping information, contribution history, and contact information such as your e-mail address and telephone number), and other information that you provide to us or that is generated through your use of the Services or interactions with The Advocator that are not otherwise publicly available.
We also may collect non-personally identifiable information about you, such as information regarding your use of the Services, your IP address, usage statistics regarding the Services, time stamps, browsing history, general geographic location, type of device you use to connect to the Services, type of operating system you use (e.g., Microsoft Windows, Google Chrome OS, Mac OS, Android or iOS), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari), the domain name of your internet service provider, and information regarding your Internet location when you see The Advocator’s ads and whether you click on such ads. We also may receive certain aggregated or anonymous information regarding users of the Services such as the age, gender, occupation, zip code, interests, Coalition preferences, and language preferences of Users of the Services, as well as information collected through questionnaires and surveys. If you are using the Services, we may collect additional non-personally identifiable information about your device such as hardware model, distinctive identifiers for your device (e.g., MAC address, IMEI number, IMSI number, etc.) certain of your selected settings with respect to your device, and the cellular carrier that provides your device with cellular services. “Non-personally identifiable information” refers to information that does not personally identify the individual to whom the information relates, such as information that is aggregated by The Advocator or a third party, or information that is not linked to contact information or other personally identifiable information of an individual.
In the event that any of the non-personally identifiable information that we collect about you is maintained, used or shared in a manner that associates it with your name, contact information or other personally identifiable information, it will be treated as personally identifiable information. If you are logged into Account on The Advocator, information such as the content you access, view, click on, download or search for when on the Services, the devices from which you access such content and the length of time for which you view same and other information regarding how you access, browse and use the Services, may become personally identifiable. In such an event, The Advocator will treat such information as personally identifiable information.
B. Information about payments
If you use the Services to donate to Coalitions, we collect information about the transaction. This does not include credit card or bank account information.
C. Device information
We collect information from or about the computers, phones, or other devices where you access The Advocator Services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices, which helps us provide consistent Services across your devices. Here are some examples of the device information we collect:
D. Information from third-party partners
We may obtain information about you from third parties and sources other than The Advocator Services, such as advertisers or social media networks for which you have approved our access to information (e.g., information from your Facebook account provided by the Facebook APIs for accessing The Advocator Services through social media networks). When you connect The Advocator’s Services to social media networks, you are authorizing The Advocator to collect, store and use such information and content in accordance with this Privacy Policy.
E. Use of Cookies
When you use our Services, we may send one or more cookies. For more information on cookies, see the Section VII below titled Cookies Policy.
III. How We Use Information
By using the information provided we can create a better user experience through personalized content. We use relevant data to help determine connections relevant to your interests and make suggestions based on your likes.
When we have location information, we use it to tailor suggestions for you and others nearby to connect. We may conduct surveys, research, test features in development, and analyze the information we have to evaluate and improve our Services, develop new features, and conduct audits and troubleshooting activities.
We use your information to send you marketing communications, communicate with you about our Services and let you know about our policies and terms. We also use your information to respond to you when you contact us.
We use the information collected to improve our advertising and measurement systems so we can show you relevant ads on and off our App and measure the effectiveness and reach of ads and services.
We use the information we have to help verify accounts and activity, to prevent fraud and abuse on The Advocator, and to promote safety and security on and off of our Services, such as by investigating suspicious activity or violations of our terms or policies. We may also use information we have collected to enforce the Terms of Service and any other contracts entered into between you and us.
E. DMCA Compliance.
We use the information collected to comply with the Digital Millennium Copyright Act or other similar legal obligations in jurisdictions around the world.
IV. How this Information is Shared
A. Information That’s Shared Publicly
When you register an Account with The Advocator, information you provide to be displayed as part of your public profile page becomes public information that can be viewed and collected by other registered users. This information may include your profile information, profile photo(s), or other forms of engagement on the Services. We may share aggregated or anonymized usage data in blog posts, press releases, or in other ways to share information about The Advocator’s usage. Aggregated or anonymized data cannot be linked back to any individual user of The Advocator Services.
B. Information That Isn’t Shared Publicly
The following Information will not be publicly disseminated nor disclosed to other Users of the Services:
• Your payment information, such as your credit card information, billing address, and card type;
• Your password information;
• Your IP address;
• Your phone number;
• Communications you send to The Advocator (e.g. when seeking support services, or reporting a problem).
C. Information That’s Shared with Users
The following Information is publicly visible and disseminated to other Users of the Services:
D. Third-party disclosure
We do not sell, trade, or otherwise transfer to outside parties your personal information. This does not include our affiliates, approved vendors, Stripe, and other parties who assist us in operating the Services, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. However, non-private, non-identifying information may be provided to other parties for marketing, advertising, or other uses.
E. Legal Requests
We may disclose personal information if we believe in good faith that disclosure is necessary to comply with state and federal laws in the U.S., the laws of other jurisdictions, as applicable, and law enforcement. Further, we reserve the right to disclose your information when we believe in good faith after reasonable inquiry that doing so is necessary or appropriate to protect ourselves from liability or allegations of misconduct; to prevent fraud, abuse, or unlawful uses; or to protect the legal rights of The Advocator, users of the Services, or others. By utilizing The Advocator, you hereby give us the right to produce any and all messages or User Content of any kind produced by you to county, state, and federal courts and/or government officials in response to a subpoena or other court order in the U.S., or in response to similar requests in other jurisdictions.
V. Data Security
The Advocator employs procedural and technological measures that are reasonably designed to help protect personal information from loss, unauthorized access, disclosure, alteration, or destruction, such as, but not limited to, firewalls, encryption techniques, and authentication procedures, among others, to work to maintain the security of your online session and personal information. In particular:
Transmissions over the Internet are never 100% secure or error-free. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal information to The Advocator or through The Advocator Services via the Internet.
VI. Payment Processing
Upon making a purchase transaction, you will also be required to provide our payment processor (Stripe) with your payment information. We do not control the collection of information by any third-party payment processor, nor do we store your credit card and/or payment information. You can see the terms of service and privacy policy for the payment processor on the Stripe site here: https://stripe.com/us/terms
and https://stripe.com/us/privacy/.
VII. Cookies Policy
A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognize your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in mobile devices. There are also technologies such as mobile device identifiers and SDK integrations to help companies recognize your device when you return to an app or otherwise use the Services.
We may ask advertisers or other partners (e.g. Google Analytics) to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.
We may use cookies to:
On your mobile device, you may have a “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests. Please note that if you choose to block cookies, doing so may impair The Advocator Services or prevent certain elements of it from functioning. Opt out instructions on Cookies are provided by the Federal Government and available at https://www.usa.gov/optout-instructions
(last visited 7/27/2017).
VIII. Third-party links
We may include or offer third-party products or services on our website. If you click on a third-party link You will be navigated away from The Advocator Services. All third-party sites have separate and independent privacy policies and terms of use. You agree that we have no responsibility or liability for the content and activities of third-party providers, and you may click on them at your own risk. However, we aim only to work with reputable companies, and we welcome your feedback.
IX. Analytics Providers
The Advocator may allow certain companies, such as analytics partners, advertisers, application developers and ad networks, to use cookies, web beacons, LSOs and other tracking technologies as described below.
The Advocator uses a variety of third-party services to help us understand the use of our Services, such as Google Analytics. These third-party service providers may collect information sent by your browser or mobile device, such as cookies or your IP address to help us measure traffic or usage trends for the Services. For example, the information generated by the cookie and other platform-specific technology about your use of our Services (including your Internet protocol ("IP") address) will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the Sites, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. We encourage you to read the Google privacy policy: https://www.google.com/policies/privacy/. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout.
X. Children’s Policy
The Services are not available to persons under the age of 18. IF YOU ARE UNDER 18 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER. If you know a registered user is under the age of 18, please report them to us.
XI. International Visitors
If you choose to provide us with information, including personal information, you understand that we are transferring it to The Advocator’s locations and systems in the United States.
XII. Fair Information Practices
Should a data breach occur we will notify affected users via email within 7 business days of our notice of any breach that could adversely affect users or for which reporting is required by law. In the case of a major breach, Users may be notified by a posting to the Services.
XIII. Email
A. Communications
We will use your e-mail address for administrative communications, customer service and membership purposes, to address copyright infringement or defamation issues, or to contact you regarding any content that you have posted to or downloaded from The Advocator Services.
B. Opt-Out
You can change which emails you receive, or opt-out, by updating your email settings or by contacting The Advocator’s customer service support team. While this removes most emails, we may also send you service-related announcements when it’s necessary to do so.
XIV. Access to Your Information
To update, correct, or delete certain of your user information and preferences, please log-in and update your account. You may also request to update, correct, or delete the personal information you have provided to us by contacting customer service. We may retain certain information as required by law or for necessary business purposes.
To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.
XV. Changes and Updates to this Privacy Policy
The Advocator reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time. If we change this Privacy Policy, we will provide you notice of these changes, such as by sending you an e-mail, posting a notice on the Services, or updating the “effective” date above. Please check this Privacy Policy periodically for those changes. Your continued use of the Services after the posting of changes constitutes your binding acceptance of such changes.
XVI. Contacting Us
Should you have any questions, concerns, or feedback relating to this Privacy Policy, please contact us at: [email protected]. Please note that email communications may not be secure. Accordingly, you should not include personal or other sensitive information in your email correspondence to the Services or to The Advocator.