Privacy Policy
Privacy Policy
Last Updated: January 1, 2018
Overview
Targeted Victory, LLC (“Targeted Victory”, “we”, “our” or “us”) provides the following services when engaging with Victory Passport™ (“Victory Passport” or “VP”): (1) a VP website that may be accessed at www.victorypassport.com (“VP Site”); (2) the Victory Passport application, which provides a donation tool for you to contribute to candidates, groups and causes (each a “Campaign”) that matter to you using a single click anywhere you see the Victory Passport banner (“VP application”). We provide this service through technology embedded on our VP Contribute Site(s); and (3) VP Contribute Sites, which are websites that we either manage, host and operate on behalf of a Campaign or own and license to (“collectively Sites”). These Sites may provide you with certain services, content, features and applications, including without limitation, the opportunity to donate, create an account, request information or fill out forms (collectively the “Services”). For purposes of this Privacy Policy, the term “VP Services” refers to the VP Site, VP application, and VP Contribute Sites and Services.
This Privacy Policy explains our practices for collection, use, and disclosure of your information, when visiting, using and/or engaging with VP Services. It also applies to any other VP Services that link to this Privacy Policy. This Privacy Policy does not apply to any other website operated by Targeted Victory, any-third party websites or information collected by any third party, including through any application or content that may link or be accessible from the VP Services.
By using VP Services, you acknowledge that your use of the Sites and/or Services and all information you provide in connection thereto, is governed by this Privacy Policy and our Terms of Service. From time to time, we may update this Privacy Policy. We encourage you to periodically check this Site for updates. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Your continued use of the VP Services affirms your agreement to any changes we make to this Privacy Policy.
CONTENTS
Voluntary Information
When you interact with us or use VP Services, Targeted Victory may collect information about you, including “personal information.” “Personal information” means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you.
We may collect Personal Information you voluntarily provide to us including your name, e-mail address, postal address, phone number, mobile number, employer name and occupation. You may provide this information when you take an action such as registering, creating or editing a user account, contributing to a Campaign, filling out a form, requesting information or for other purposes. As part of the VP Services, we also may collect your credit card and billing information that you provide to us in connection with VP Services. Additionally, we may collect demographic information such as gender, date of birth, occupation, employer name and zip code. We will use such information in accordance with this Privacy Policy.
Automatically Generated Information
As you navigate through and interact with VP Services, we and our service providers may use automatic data collection technologies to collect non-personally identifiable information that is generated automatically while you using the VP Services, other websites, mobile websites and/or mobile applications or elsewhere on the Internet in order to provide content and advertisements about goods and services of interest to you across those various devices.
This non-personally identifiable information includes, but is not limited to, web pages visited before and after visiting the VP Services, date and time, logs, domain type, type of mobile device you use, your device’s unique ID links you click on, interactions with an advertisement delivered by us or a third-party advertising technology vendor and other communication data regarding the resources you access and use in connection with the VP Services. We may also collect your IP address, which is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet.
This information is generated by the following technologies:
Cookies: This type of information may be collected using different types of technologies, such as cookies and pixels. “Cookies” are small pieces of information that are stored by your browser. You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our VP Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you direct your browser to our Website. More information on how to disable Cookies is located under “Your Choices” below.
Web Beacons: Our VP Services and our related e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Site statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
Google Analytics: We use tools, including Google Analytics – a web analytics service provided by Google, Inc. (“Google”) – to help analyze how users use the VP Services. This information is generated by cookies and transmitted to Google (including IP address). This information is then used to evaluate visitors’ use of the VP Services and to compile statistical reports on VP Services activity for us. Google Analytics collects information anonymously. You can opt out of Google Analytics without affecting your use of the VP Services. For more information about Google Analytics and to opt out of use of your information by Google Analytics, visit Google Analytics Opt-out Browser Add-On.
Information Use and Sharing
Use of Personal Information
We may use your Personal Information that you submit to us via the VP Services in order to: present our VP Services and its contents to you; provide you with the VP Services or other information, products or services that you request; provide you with information, products, or services we think might be of interest to you; fulfill any other purpose for which you provide it; to administer special offers from Targeted Victory or its third party providers; as provided in this Privacy Policy or in any other way we may describe when you provide the information and for any other purpose with your consent; provide you with notices about your User Account, for example notifying you of reoccurring donations; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; to notify you about changes to our Sites or any products or VP Services we offer or provide; and for our everyday business purposes such as service improvements and security, operations, fraud detection, analytics and optimization, payment processing, and enforcement of our Terms of Use.
Submitting your e-mail address anywhere via the VP Services will result in your e-mail address being added to the Targeted Victory e-mail list as well as the Campaign’s e-mail list. We may use your e-mail address to contact you about our own or a third-parties’ goods and services that may be of interest to you. We may also use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. More information regarding how to opt-out of receiving e-mails from us can be found under the “Your Choices” section below.
Sharing of Personal Information
We may share your Personal Information outside of Targeted Victory if (1) you authorize us to do so, (2) it is necessary to allow our service providers, contractors, agents or other third parties to provide products or services for us, such as processing payments or donations, storage, fulfillment of promotional merchandise, distribution of e-mails, fraud prevention services, etc., (3) it is necessary in order to provide our products or services or our clients’ products or services to you (and contacting you when necessary), (4) subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, (5) subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of Targeted Victory or the merger of Targeted Victory into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Targeted Victory is not the survivor, (6) it is necessary in connection with other business purposes including, without limitation, responding to your inquiries or requests for information or services, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends, dispute resolution, credit checking and debt collection, (7) it is necessary to disclose in order to protect or defend our rights or property or those of our users, (8) it is necessary to disclose in order to protect the personal safety of our users or the public, (9) it is necessary for us to provide it to our attorneys, accountants, regulators, auditors or other advisors, or (10) otherwise as required or permitted by law or required to comply with legal process served upon us, our agents, clients, representatives or our affiliates.
Use and Sharing of Non-Personally Identifiable Information
We may use Cookies to compile aggregate non-personally identifiable data about the Sites’ traffic and Sites’ interaction so that we can offer better experiences and tools in the future. We may also share non-personally identifiable information with companies such as advertisers, agencies, ad networks, or exchanges to enable them to analyze user behaviors or to customize the ads that you encounter.
This Cookie technology is provided by our service providers, which allows us to gather information about you, speed navigation, keep track of items and to gather anonymous traffic data that we may use to enhance the VP Services, marketing, and other internal purposes. We may also use non-personally identifiable information to better tailor advertisements and other content in an effort to create a more relevant experience for each person that visits the VP Services or elsewhere on the Internet. This non-personally identifiable information may also be used to predict responses to advertisements, to help determine which ads perform best and which content is most appropriate for different individuals, to measure and optimize the effectiveness of advertisements, and to provide aggregate reporting to advertisers and clients and for our and their internal purposes. We may use various website analytics tools and technologies, including Google Analytics, regarding activities on our the VP Services that require storage of web session data. The overall aim of these tools is to aid in making the VP Services easy to use, to proactively identify and correct error conditions and to provide more relevant advertising and content to you. These tools and technologies are also used to assist visitors who report problems in the use of our Sites and VP Services. Stored web session data is used in accordance with this Privacy Policy.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction, and in accordance with applicable law.
Your Choices
You may unsubscribe to Targeted Victory e-mails at any time by opting out of e-mail subscriptions with the “unsubscribe” link included in each e-mail. Your e-mail address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.
Advertising
We, along with our third-party service providers, may use non-personally identifiable information to provide more relevant advertising and content. You can stop from the collection of certain types of information that provide more tailored online ads and messages to you by clicking here.
You can also opt out and learn more information about your choices with respect to data collection by visiting the site of the Digital Advertising Alliance, which can be found here: http://www.aboutads.info/choices. You can also opt out by visiting the site of the Network Advertising Initiative, which can be found here: http://www.networkadvertising.org/choices/.
Disabling Cookies
You may manage how your mobile device and browser handle Cookies by adjusting their respective privacy and security settings. For example, the “Help” portion of the toolbar on most browsers may also tell you how to prevent your browser from accepting Cookies, how to have the browser notify you when you receive Cookies, and how to disable Cookies altogether. However, mobile devices and browsers are different, so please refer to instructions related to your device and browser to learn about Cookie-related and other privacy and security settings that may be available. Note that if you reject or block Cookies, it may affect your ability to enjoy the full functionality and experience of our VP Services.
Mobile Requests/ SMS Services
If you request to receive information to your mobile phone, you consent to receiving communication from Targeted Victory via your mobile device. This could include text or SMS messages. By requesting information to your mobile phone, we may obtain the following information from you in connection with our SMS Service: your cell phone number, your carrier’s name, and the date, time and Content of your messages, as well as other information that you provide.
You are able to opt out from receiving SMS or text messages at any time by texting STOP or HELP.
Please review our Terms of Use for further information regarding the SMS Services.
Accessing Your Information
You may request that we provide you the Personal Information we hold about you, update your information, or ask us to remove your information, or to correct any inaccuracies in such Personal Information by sending an email to info@targetedvictory.com. We will use reasonable efforts to deal with your request within a reasonable time.
If you remove, update or change your Personal Information, such information may remain viewable in cached and archived pages, or might have been copied or stored by our third party service providers carrying out the requested Services. Proper access and use of VP Services, is governed by our terms of use Terms of Service.
Third-Party Platforms
Third-Party Links and Services
For your convenience, we may include or offer third-party offers, products, links or services via the VP Services. Third parties may use Cookies or other technologies to serve ads on other websites based on your visit to the VP Services and other websites on the Internet. We cannot be responsible for the privacy practices of any websites or pages not under our control, or how they handle your Personal Information. We do not endorse any of these websites or pages, the services or products described or offered on such websites or pages, or any of the content contained on those websites or pages. Please also be aware that this Privacy Policy does not apply to Third-Party Sites. If you provide any information to any third parties (e.g., social media services, payment providers), different rules regarding the collection and use of your Personal Information may apply. As such, we strongly encourage you to read the privacy statements and terms and conditions of any linked or referenced websites you enter. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these websites.
Social Media Platforms and other Websites
Social Networking. Targeted Victory maintains a presence on third-party social networking sites such as Twitter, LinkedIn, Facebook and others. Targeted Victory does not control or have responsibility for the collection, tracking, use, or disclosure of your information (including your Personal Information or non-personally identifiable information) gathered through these social networking sites, including through the Targeted Victory’s pages or profiles within those sites, or otherwise as a result of your participation in social networking sites. Third-party social networking sites and advertisers on these sites, including on the Targeted Victory’s pages or profiles within these sites, are not obligated to follow or apply this Privacy Policy or our Terms of Service. If you have any questions about an advertisement or other targeted content, you should contact the responsible social networking provider directly.
Social Community Features. Any information, communications, or material of any type or nature that you submit to our Sites (including, but not limited to any of our pages contained on a social media platform or website such as Facebook or Twitter) by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of any social media platform or website and we are therefore not responsible for any content or Submissions contained on such sites and platforms. By visiting any of our pages or websites that are contained on a social media platform or website, you are representing and warranting to us that you have reviewed the applicable privacy policy and terms of use of such platform or website and that you will abide by all such provisions contained therein. Additionally, in the event that we offer a message board or any other interactive or social-type feature on a website administered directly by us, please be aware that these areas may allow you to publicly post, and share with other users, certain messages, content, or other information (e.g., stories, pictures, ingredients, tips, etc.). Although we may take certain precautions to protect those who use these areas of one of our websites, we encourage you to be wary of giving out any Personal Information in such public forums. The information you post can be collected and used by people you don’t know. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.
Suggesting the Site to a Friend
If you elect to use any feature that includes suggesting a page to a friend or to inform a friend about VP Services or solicit donations or pledges or otherwise communicate, Targeted Victory may ask for your friend’s name and e-mail address. The VP Services may automatically send the friend a one-time e-mail inviting them to visit the Sites or otherwise provide the information requested by you. Targeted Victory will store and use this information in accordance with this Privacy Policy. In order to refer a friend, you should first obtain the consent from the person being referred to provide information on their behalf and inform them that they will be receiving a communication from us. Your friend may contact Targeted Victory at info@targetedvictory.com to request the removal of this information from our databases.
Security
We employ and maintain commercially reasonable technology and security measures designed to protect your Personal Information. However, no data transmission over the Internet can be guaranteed as 100% secure. As a result, while we strive to protect your information against unauthorized use, disclosure, alteration or destruction, we cannot ensure or warrant the security of any information you transmit to us or receive from us. In addition, you acknowledge that Targeted Victory is not liable for any losses in the event your Personal Information is revealed or stolen due to force majeure or security issues not caused by us. If you have any questions about the security of the VP Services, you can contact us at info@targetedvictory.com.
Your California Privacy Rights and Do Not Track Disclosures
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact Targeted Victory on our Sites or write to us at (with a reference to California Disclosure Information):
Targeted Victory, LLC
Attn: Counsel
1100 Wilson Blvd., Fl. 10
Arlington, VA 22209
E-mail: info@targetedvictory.com
We will respond to such requests for information access within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.
Like many other websites and online services, Targeted Victory does not currently alter its practices when it receives Do Not Track signals because there is no consensus among industry participants as to what “Do Not Track” means in this context. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
Children
You must be 18 years old to use VP Services. We strongly encourage parents and guardians to regularly monitor and supervise their children’s online activities. Our Sites are not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this Sites or on or through any of its features/register on the Sites, make any purchases through the Sites, use any of the interactive or public comment features of these Sites or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information as soon as reasonably possible. If you believe we might have any information from or about a child under 13, please contact us at info@targetedvictory.com.
Feedback
We appreciate your questions and comments about and the VP Services and welcome your e-mails and questions. We will share your messages with those within our organization who are most capable of addressing the issues contained in your message. We may archive your message for a certain period of time or discard it, but your e-mail address and message will only be used in accordance with this Privacy Policy.
Contests, Sweepstakes and Other Promotions
You may wish to participate in contests, sweepstakes and other promotions that we may offer from time to time. Through these promotions, you may choose to participate in activities such as sharing information found on our Sites with others and sending e-mail invitations. In connection with any contests, sweepstakes and other promotions that we may offer from time to time via our Sites, we may use the information you provide to administer the contests, sweepstakes and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our or our clients’ products and services or our partners may use such information to communicate with you about the contests, sweepstakes or other promotions or their products and services. If you choose to participate in these promotions, and are eligible to do so, we may ask you for information such as your name, e-mail address, date of birth and telephone number.
Visiting from outside of the United States
The VP Services are intended for residents in the United States. If you are visiting our Sites from outside of the United States, please be aware that your Personal Information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our VP Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy. You agree that the laws of the United States and the state of [Virginia] will govern the processing of your Personal Information, including any obligations of security and third-party sharing.
Contact Us
Please contact us if you have questions about our Privacy Policy at: info@targetedvictory.com.