Effective as of: May 17, 2012
The American Civil Liberties Union of California (“ACLU of California”) has a history of being at the forefront of protecting individual privacy, and we are particularly committed to protecting the personal information that you provide and entrust to us when using the ACLU of California’s websites. This online privacy statement (the “Privacy Statement”) describes how we treat all user data collected by the ACLU of California during your visit to the ACLU of California Site, both technical data that is automatically collected and voluntarily submitted data. (The ACLU of California comprises the American Civil Liberties Union of Northern California, the American Civil Liberties Union of Southern California, and the American Civil Liberties Union of San Diego & Imperial Counties.)
For purposes of this Privacy Statement, the “ACLU of California Site” is the website whose home page is acluca.staging.wpengine.com, and includes all web pages whose domain name contains the following: acluca.staging.wpengine.com and some pages of www.aclu.org/secure where a link to this privacy statement exists. [This is not the privacy statement for any blogs, forums or social networking sites where ACLU of California has a presence that are on websites other than the ACLU of California Site. Further, this is not the privacy statement for the websites of the national operations of the ACLU, the American Civil Liberties Union or the American Civil Liberties Union Foundation (“ACLU National”) or for any ACLU local affiliates other than ACLU of California, and you should refer to the privacy statements on those organizations’ websites or contact those organizations to learn the manner in which they treat information you provide to them through their websites’ (or provide to them in any manner other than through the ACLU of California Site).
The ACLU of California may occasionally update this Statement. We will post any changes on this web page, so be sure to check back periodically. If we do make material changes, we will post a notice on our home page that the Privacy Statement has been modified and provide a link to the revised Privacy Statement. Any information that you submit after a change has been posted will be subject to the new provisions.
User Data We Collect
We collect two types of user data: (1) technical data that is automatically collected from all visitors to the ACLU of California Site (“Automatically Collected Data”); and (2) data that you voluntarily submit to us (described below under “Voluntarily Submitted Data”).
Automatically Collected Data We automatically collect Internet Protocol (“IP”) addresses and domain names of the originating visitor’s computer on our server and may know some information you have previously provided through cookies. (See the section on “Cookies” below for more information.) We also track the number and frequency of hits per page as well as length of website visit, using IP addresses and/or session cookies, but we do not associate any individual IP address or session information with any other personally identifying information except to detect security intrusions or certain unlawful activity. We use this information to perform website traffic analysis so we can better improve the ACLU of California Site experience.
In addition, if you come to the ACLU of California Site from a website link, we may also identify the source of that link so that we can evaluate what content is persuading web users to become involved in the ACLU of California’s work.
Voluntarily Submitted Data We may collect Voluntarily Submitted Data, including personal data, that you voluntarily provide, such as your name and postal address, phone number, e-mail address, and similar information, and transactional information, such as giving and action-taking history, when you participate in certain activities on the ACLU of California Site, including (but not limited to) when you:
- join or renew your membership to the ACLU of California;
- make an additional contribution to support the ACLU of California;
- sign up for our ACLU of California e-mail network;
- send correspondence, place a call, or inform us of a call to your government representative, or send correspondence to a friend (e.g., when you tell-a-friend or send an e-card) or to other targeted representatives through the ACLU of California Site;
order items from the ACLU of California store;
- register for our message board;
- register online for an event;
- participate in one of our online petitions, forms or surveys;
- post a blog comment;
- submit feedback to the ACLU of California; or
- participate in any activity that requires your Voluntarily Submitted Data.
When you send correspondence to a friend, your friend’s email address is only captured by us temporarily in order to complete your send request.
We may transfer a Long-term Cookie only in circumstances in which you are notified prior to the cookie being stored, for example, when you select a “remember” option on the ACLU of California Site. If you select one of these options, a Long-term Cookie will be stored on your computer’s hard drive solely for the purpose of automatically filling in the information you have asked to be remembered, for example, automatically filling in your password when you log in to the ACLU of California Site or your postal address when you write a letter to your representative. These “remember” options are offered only for your convenience and are completely voluntary. If you do not select a “remember” option, we will not transfer a Long-Term Cookie to your computer’s hard drive.
We may use Session Cookies whenever you visit the ACLU of California Site for ouir website traffic analytics application and the Site’s interactive applications, such as in our online advocacy. Session Cookies last only as long as your session on the ACLU of California Site. They expire when the session ends and are not written onto your computer’s hard drive. We also use Session Cookies in e-mails containing the HTML-format. If you select “text-only” format preference, emails sent to you will not contain any Session Cookies.
We also may use Short-term Cookies to facilitate some of our website analysis and functionality, such as maps and videos. These Short-term Cookies are set to expire within one hour of their being placed on your hard drive.
How We Use The Data We Collect
In addition to the uses described above, we use Automatically Collected Data to identify the source of user traffic (for example, umich.edu, or aol.com), but we do not tie this information to individual users in our database. We use data that indicates which sections of the ACLU of California Site are most visited, so that we can evaluate the popularity of our different web pages and continue to improve the ACLU of California Site. We do not link any Automatically Collected Data with the Voluntarily Submitted Data you provide to us except to detect security intrusions or certain unlawful activity.
We use your Voluntarily Submitted Data for various purposes:
- To fulfill the request for which you specifically provided the data, including sharing the data with its intended recipient (e.g., delivering a petition you sign or a letter you wish to send to the recipient of the petition or letter);
- To analyze actions taken through our website;
- To periodically communicate with you concerning ACLU of California matters, such as delivering to you information and updates on our activities and action alerts, if you have not opted out of receiving such information and updates;
- To indicate you as the author of any comment you post, including on any ACLU of California Site blog or forum, when you opt to identify yourself as the author or when posting such comment requires such identification, and to display any personally identifying or other information you voluntarily include in such comments;
- To personalize the content that you see based on the activities and products that you have selected on the ACLU of California Site;
- To allow you to set and change user preferences;
- To allow you to renew your membership in the ACLU of California;
- To offer you other ways to support the ACLU of California, including solicitations for additional contributions if you have not opted out of receiving such communications;
- To confirm your contribution to the ACLU of California;
- To confirm your registration to an ACLU of California event;
- To confirm a purchase;
- To respond to an inquiry or feedback you have made to the ACLU; and
- To follow up with you with an email specific to an activity you have participated in or intend to participate in.
If your Voluntarily Submitted Data includes a U.S. zip code or state and you are a member, donor or subscriber to ACLU of California information, unless you choose otherwise (see Your Ability to Choose below), we may also share your Voluntarily Submitted Data with ACLU National, which may use that information for any purpose for which we may use that information as described in this Privacy Statement and, if you are a member, donor or subscriber to ACLU of California and you list as your address a U.S. address that is within the geographic region of another local ACLU affiliate, we may share your information with that local affiliate which may use that information to:
- To periodically communicate with you concerning local affiliate matters, such as delivering information and updates on the local affiliate’s activities, action alerts concerning local matters and invitations to local events, if you have not opted out of receiving that information;
- To confirm your registration to an event;
- To follow up with you with an email specific to an activity you have participated in or intend to participate in; and
- To offer you other ways to support the ACLU, including solicitations for additional contributions, if you have not opted out of receiving such communications.
The ACLU of California Site is hosted by servers in the United States. Accordingly, if you are located outside of the United States, the Voluntarily Submitted Data you provide to us will be transferred to the United States. By submitting your Voluntarily Submitted Data, you consent to its transfer and storage in the United States and its use in accordance with the purposes for which it was originally collected (see below regarding third-party sharing of Voluntarily Submitted Data from non-U.S. residents).
If you are a U.S. resident, we may also from time to time combine your Voluntarily Submitted Data with some publicly available data collected from third parties to improve our services to you and for our own internal marketing, communications, and fundraising purposes.
Third Party Sharing We share your Voluntarily Submitted Data with third-party service providers who fulfill your orders or transactions, contact you on our behalf, or facilitate some other aspect of ACLU of California activities, services or products, including those third-party service providers who collect, process, store and transmit information we collect on this website and those third-party service providers we use to assist us in our fundraising and communications efforts. These service providers have access to your Voluntarily Submitted Data solely for the purpose of providing these services to us on our behalf, and they are contractually prohibited from sharing your Voluntarily Submitted Data with third parties other than subcontractors assisting them in their providing these services to us who also are contractually prohibited from sharing our Voluntarily Submitted Data with any other third parties. Please note that we do not share data from non-U.S. residents with any other third parties (except where required by law, see below), even if a non-U.S. resident has subsequently authorized such use, for example, by checking an opt-in request.
We may also share the Voluntarily Submitted Data of members and donors who are U.S. residents with other non-profit organizations and publications (“Sharing Organizations”), but never to any partisan political groups or to groups whose programs are incompatible with ACLU of California policies. We never give your Voluntarily Submitted Data directly to the Sharing Organizations; instead we send the list to a third-party service provider that prepares the mailing for the Sharing Organization (and that is contractually bound to use your Voluntarily Submitted Data only for this purpose and not to share it with any third parties other than subcontractors assisting them in their providing these services to us who also are contractually prohibited from sharing our Voluntarily Submitted Data with any other third parties). The Sharing Organizations never see our list and never know what names and related contact information are on it other than the names and contact information of those individuals who respond to the Sharing Organizations’ mailing. Exchanging lists can enable the ACLU of California to expand our membership base. However, you can choose to opt out of having your data shared. To learn more, read the section on “Your Ability to Choose” below.
Finally, we may disclose and use Voluntarily Submitted Data regardless of where you reside in special circumstances when it is necessary to enforce our User Agreement or this Privacy Statement, or when we, under what we hope to be extraordinary and infrequent circumstances, in good faith, truly believe that the law requires us to disclose your Voluntarily Submitted Data to third parties.
Except as described in this Privacy Statement, we will not share your Voluntarily Submitted Data with any third party unless we first notify you and offer you an appropriate choice to consent to such further use, for example, through an opt-out or opt-in request.
Third-Party Functionality As discussed in the preceding section, to support certain functions carried out on the ACLU of California Site, the ACLU of California uses third-party service providers. In limited instances with respect to specific optional functions on the ACLU of California Site, those third parties may have data collection, use or security procedures that differ from the practices outlined in this Privacy Statement and that may impact users of those optional functions. For example, a third-party service provider may support a specific web tool on the ACLU of California Site, such as a web game, that appears within the ACLU of California Site, even though that tool is actually on the website of the third-party service provider. Any time a third-party service provider’s data collection, use or security practices differs from the data collection/use practices described in this Statement in a manner that would impact users of the ACLU of California Site, we will either describe on the pages of the ACLU of California Site where such optional functions appear the specific data collection, use or security practices of such third-party service provider that would apply if you elect to use that optional function or we will provide a link to that third-party service provider’s privacy statement.
In furtherance of its mission, the ACLU of California forms, works with and joins Coalitions of organizations and individuals collectively working on issues related to the ACLU of California’s mission (“Coalitions”). The ACLU of California does not share Voluntarily Submitted Data you submit to the ACLU of California Site with those Coalitions unless you have opted in to doing so, including by submitting Voluntarily Submitted Data to the Coalition through the ACLU of California Site or by taking an action on the ACLU of California Site that is specifically designated as an action of the Coalition (unless it states on the website page where you take such action that Voluntarily Submitted Data will not be shared with the Coalition). Once you have opted in to doing so (or have voluntarily submitted information to a Coalition in any manner other than through the ACLU of California Site), that information is information you are submitting to the Coalition itself. Unless specifically stated otherwise on the ACLU of California Site with respect to a Coalition action or a collection mechanism for a Coalition, this Privacy Statement does not address the treatment of personal information, including Voluntarily Submitted Data, that is submitted to a Coalition. Please contact the Coalition or review the privacy statement on the Coalition’s website, if it has one, to learn about the treatment of the information you provide to a Coalition.
Your Ability to Choose
When you provide us with your Voluntarily Submitted Data on the ACLU of California Site, you can let us know that you do not wish to receive our email communications by un-checking or not checking the subscription request box on the form you are completing, by un-checking or not checking the subscription request box on our User Preference Page, by unsubscribing from further email communications of a specific type following receipt of an email of that type, or by contacting us via postal mail sent to Web Content Manager, 39 Drumm Street, San Francisco, CA 94111.
You can opt out of having your Voluntarily Submitted Data shared with Sharing Organizations on the online form you are filling out or thereafter by emailing us at firstname.lastname@example.org or by contacting us via postal mail sent to Membership Department, ACLU of Northern California, 39 Drumm Street, San Francisco, CA 94111.
Again, please remember that if you are a non-U.S. resident, we will not use your Voluntarily Submitted Data for any purpose other than the one for which it was originally collected regardless of whether you check or un-check a box.
We do not knowingly collect information from children under the age of 13.
The Voluntarily Submitted Data we collect about you is stored on a secure, password protected server and only authorized personnel have access to your information. We use industry-standard encryption technologies with respect to the receipt and transfer of Voluntarily Submitted Data you submit to us on the ACLU of California Site and only authorized personnel have access to your information. Nevertheless, despite our best efforts, no transmission over the Internet and no data storage method can be guaranteed to be 100% secure.
Updating Your Data
To update your Voluntarily Submitted Data or to make corrections, you can do so by using User Preference Page, or by sending us the update via postal mail sent to Web Content Manager, ACLU of Northern California, 39 Drumm Street, San Francisco, CA 94111.
Comments and Questions
If you have any questions, comments or concerns about this Privacy Statement or our data collection practices or to request that we delete your Voluntarily Submitted Data, you can email us at email@example.com or send us your questions or comments via postal mail sent to Web Content Manager, ACLU of Northern California, 39 Drumm Street, San Francisco, CA 94111.