Privacy Notice

FRAISER PRIVACY NOTICE

Last Updated: 1/28/2022 

Fraiser, Inc. (“Fraiser,” “we,” “our,” or “us”) is dedicated to assisting our clients, which includes political campaigns and nonprofit entities, optimize their communications with voters and potential donors.  We’ve developed this Privacy Notice to describe how and why we collect, use, and share your personal information.  


Our Services:  This Privacy Notice applies to our collection of personal information through our website at https://www.fraiser.org/ (“Website”), and from any other interactions you have with us (collectively, our “Services”). 

Please note that this Privacy Notice does not apply to our processing of information about employees or contractors. 

Region Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions, or states. Please refer below for disclosures that may be applicable to you:

  • If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
  • If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at privacy@fraiser.org to submit such a request.

HOW WE COLLECT AND USE PERSONAL INFORMATION

Personal Information:  When we use the term “personal information,” we mean any information that can be used to identify you, directly or indirectly, as an individual person.

We collect personal information in connection with your visits to and use of the Service. This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically, such as through the use of cookies and other technologies.

Information You Provide  

We may collect and use personal information you provide in the following ways:

  • Registration.  If you register for an account with our Services, we may collect your name, email address and account credentials.  We use this information to administer your account, provide you with the relevant services and information, communicate with you regarding your account and your use of the Services, and for customer support purposes.  
  • Transactions.  If you complete a transaction through the Services, we may collect information relevant to the transaction such as transaction amount, sender address, and recipient address.
  • Communications. If you communicate with us through any paper or electronic form, we may collect your name, email address, mailing address, phone number, or any other personal information you choose to provide to us.  We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.  If you register for our newsletters or updates, we will communicate with you by email. To unsubscribe from promotional messages, please follow the instructions within our messages and review the Online Privacy Choices section below.  

Information We Collect Online Automatically

As is true of most digital platforms, we collect certain personal information automatically when you visit our Services, including:

  • Log File Data, including your internet protocol (IP) address, operating system, browser type, browser id, date/time of visit, and pages visited.
  • Analytics Data, including the electronic path you take to our services, through our services and when exiting our services, as well as your usage and activity on our services, such as the links and objects you view, click or otherwise interact with (also known as “Clickstream Data”). 
  • Location Data, including your general geographic location based on your IP address or more precise location when accessing our online services through a mobile device.
  • Cookies and Other Data Collection Technologies.  We and our service providers use cookies, scripts and similar technologies to manage the Services and to collect information about you and your use of the Services.  These technologies help us to recognize you, customize or personalize your experience, advertise products or services to you and analyze the use of our Services to make them more useful to you.  These technologies may also allow us to collect demographic and statistical data and provide this information to our service providers to help deliver their services.  Most internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences.  For information on how to do this, access the “help” menu on your internet browser, or access http://www.aboutcookies.org/how-to-control-cookies.  Please note, however, that disabling our cookies may mean that you will not be able to take full advantage of our Services.
  • Google Analytics.  We use “Google Analytics” to collect information about your use of the Website.  Google Analytics collects information such as how often users access the Services, what pages they access when they do so and what other sites they used prior to using the Services.  Google uses the data collected to track and examine the use of the Services, to prepare reports on its activities and share them with other Google services.  To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page.

Information from Third Party Sources

We may receive personal information about you from other users or our business partners and service providers and combine this information with other information we have.

  • Information from Other Sources.  We may obtain information from other sources, including through third-party information providers, our customers, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined personal information. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.  

Other Uses of Personal Information


In addition to the uses described above, we may collect and use personal information for the following purposes:

  • To create, maintain, improve, and operate the Website and Services.
  • To enable our clients to provide you with emails or communications containing information such as alerts or event registrations that may be of interest to you.
  • To personalize your user experience.
  • To communicate with you to provide technical or administrative support.
  • To conduct, manage, and grow our organization.
  • To market and advertise to you, such as to provide information and updates on our Services or other news or information about Fraiser. 
  • To analyze, research, investigate and improve the use of our Services.
  • To comply with our obligations and enforce our rights arising from any contracts we have with our customers.
  • To prevent, investigate, and provide fraud notifications, unlawful or criminal activity, unauthorized access to or use of personal information, our data system services, and to meet governmental and institutional policy obligations.
  • To investigate and resolve disputes and security issues and to enforce our agreement, including our Terms of Service.
  • For any other lawful, legitimate business purpose.

HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION

We may share your personal information in the following ways:

  • Affiliates. We may share personal information with other companies owned or controlled by Fraiser, and other companies under common ownership with Fraiser, which include subsidiaries (i.e., any organization we own and control) or parent companies (i.e., any organization that owns or controls us) and any subsidiaries it owns. 

 

  • Our Clients.  We may share personal information with our clients, such as political campaigns and nonprofit entities, to help them to optimize their communications with voters and potential donors and to communicate with you regarding issues that may be of interest. 


  • Service Providers.  We share personal information with third-party service providers who perform services on our behalf, such as technology providers (including web and mobile platforms and hosting providers, email communications providers, analytics providers and data storage providers).  
  • Regulatory or Legal Requirements, Safety and Terms Enforcement.  We may disclose personal information to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations.  We may also disclose personal information to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you or any other person, to protect against fraud or credit risk, or to enforce our legal rights or contractual commitments that you have made. 
  • Business Transfers.  We may disclose personal information as part of an organizational business transaction, such as a merger, acquisition, joint venture, financing, or sale of organizational assets and may transfer personal information to a third-party as one of the business assets in such a transaction.  We may also disclose personal information in the event of insolvency, bankruptcy, or receivership. 
  • Consent. With any other entity disclosed to you at the time we collect your information or with your consent.

THIRD-PARTY TRACKING AND ONLINE ADVERTISING

We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services, to collect information about your use of our Website over time so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use.  Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information.  This information is used to display targeted ads on or through our Services  or on other websites, apps, or services. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. We may also display targeted advertising to you through social media platforms, such as LinkedIn, Facebook, Twitter, Google, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services or our clients’ services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.

Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

ONLINE PRIVACY CHOICES

You have some choices regarding how we use your personal information, including the following:

  • Modifying or Deleting Your Information.  If you have questions about reviewing, changing, or deleting your information, you can contact us directly at privacy@fraiser.org. If you are inquiring about information collected in by one of our business partners, please contact our business partner for more information.  We may not be able to change or delete your information in all circumstances.
  • How to Control Your Email Communications Preferences.  You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in the email.  You may not opt-out of Service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Website, technical and security notices).

CHILDRENS PRIVACY

We do not knowingly collect or solicit personal information from children under the age of thirteen, nor is this website targeted towards children under the age of thirteen. In the event we learn that we have inadvertently collected personal information from a child under age thirteen, we will delete that information as quickly as possible.  If you believe that we might have received information from a child under thirteen, please contact us at privacy@fraiser.org.

THIRD PARTY WEBSITES AND SERVICES

The Services may contain integrations or links to third party websites or services, including those of our business partners.  By interacting with these third parties, you are providing information directly to the third party and not Fraiser.  Please note that Fraiser is not responsible for the privacy practices of these third parties or any entity that it does not own or control.  We encourage you to review the privacy policies and online terms of those third parties to learn more about how they handle your personal information.

CONTACT US

If you have any questions about this Privacy Notice or the Services, please contact us at:

Email: privacy@fraiser.org.

CHANGES TO OUR PRIVACY NOTICE

This Privacy Notice is subject to occasional revisions. Fraiser will update this Privacy Notice in a timely manner if anything is updated or changed and will repost the notice on the Website with an updated effective date at the top.  We will notify you about material changes in the way we treat personal data by sending a notice to the primary email address specified in your Learners account and/or by placing a prominent notice on our Website. We encourage you to check this page periodically to stay informed about how we are processing personal information.

FRAISER ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES

Last Updated: 1/28/22

Scope of Disclosures

These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California (“consumers” or “you”). 

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). 

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA. 

Personal Information Disclosures

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include information that is made publicly available from government records, that is deidentified or aggregated such that it is not capable of being associated with you, or that is otherwise excluded from the CCPA’s scope. 

These CA Disclosures also do not apply to information relating to our employees, contractors, applicants and other personnel.  In addition, we often act as a “service provider,” as defined in the CCPA, processing personal information on behalf of our customers, and these CA Disclosures do not apply to the personal information processing we perform as a service provider. 

Collection and Use of Personal Information

In the last 12 months we have collected and disclosed for a business purpose the following categories of personal information: 

  • Identifiers, such as full name, city, state, zip code, email address, cell number
  • California Customer Records (Cal. Civ. Code § 1798.80(e)), such as name and mailing address 
  • Internet/Network Information, such as log data (including operating system and browser type) and clickstream data (including your usage and activity on our web sites and online services)
  • Inferences, such as predictions about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, and aptitudes

We collect this information directly from you, from your browser or device when you interact with our services, from our clients or their agents, from information providers and from other publicly available sources. For more information about the personal information that we collect and how we collect it, please refer to the How We Collect and Use Personal Information section of our Privacy Notice.  

We collect personal information from and about you for a variety of purposes. For example, we use personal information to communicate with customers about our services, to provide customers with our services, and to otherwise operate our business. For more information about our use of Personal Information, please refer to the How We Collect and Use Personal Information section of our Privacy Notice.  

Disclosure and Sale of Personal Information

As described in the How We Share and Disclose Personal Information section of our Privacy Notice, we share personal information with Fraiser affiliates and with a variety of third parties for business purposes, or we may sell your personal information to third parties, subject to your right to opt out of those sales. 

In the last 12 months, we have disclosed for a business purpose or sold all categories of personal information outlined in the Collection and Use of Personal Information section above to:

  • Our affiliates 
  • Our service providers 
  • Our clients, which include political campaigns and non-profit entities 

For more information about how we share personal information, please refer to the How We Share and Disclose Personal Information section of our Privacy Notice

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law): 

The Right to Know You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity: 

  • The specific pieces of personal information we have collected about you; 
  • The categories of personal information we have collected about you; 
  • The categories of sources of the personal information we have collected about you; 
  • The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; 
  • The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and 
  • The business or commercial purposes for collecting or, if applicable, selling personal information about you.
The Right to Request Deletion You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out
of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. 
The Right to 

Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of the rights described above. 

 

However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

How to Exercise Your California Privacy Rights

To Exercise Your Right to Know or Right to Deletion

To exercise your right to know and/or right to deletion, please submit a request by: 

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your Slushy account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address, address, order number, and/or date of last interaction with customer service.

In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.

To Exercise Your Right to Opt Out of Personal Information Sales

Unless you have exercised your Right to Opt Out of Personal Information Sales, we may sell personal information to third parties for monetary or other valuable consideration. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.

To exercise your Right to Opt Out of Personal Information Sales, please submit a request by clicking the following link:

Do Not Sell My Personal Information

You do not need to create an account with us to exercise your right to opt out of personal information sales. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and to track compliance with your opt out request. We will only use personal information provided in an opt out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. 

Once you make an opt-out request, you may change your mind and opt back into future personal information sales at any time by contacting us at: privacy@fraiser.org

Minors Under 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Authorized Agent

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf by: 

  • For requests to know or delete personal information: 
    • Receiving a power of attorney valid under the laws of California from you or your authorized agent; or
    • Receiving sufficient evidence to show that you have:
      • Provided the authorized agent signed permission to act on your behalf; 
      • Verified your own identity directly with us pursuant to the instructions set forth in these Disclosures; and 
      • Directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf. 
  • For requests to opt out of personal information sales: Receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf. 

We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to privacy@fraiser.org