FRAISER PRIVACY NOTICE
Last Updated: 01/01/2023
Fraiser, Inc. (“Fraiser,” “we,” “our,” or “us”) is dedicated to assisting our clients, which include 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.
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.
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.
- 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.
- 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 visiting NAI’s online resources at http://www.networkadvertising.org/choices.
We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in this Privacy Notice, and in accordance with our business purpose and applicable law. For example, the criteria used to determine the period for which personal information about you will be retained varies depending on the business purpose under which we process the personal information:
- Contract. Where we are processing personal information is based on contract, we generally will retain your personal information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
- Business Purpose. Where we are processing personal information based on our business purpose, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account your fundamental interests and your rights.
- Consent. Where we are processing personal information based on your consent, we generally will retain your personal information until you withdraw your consent, or otherwise for the period of time necessary to fulfil the underlying agreement with you or provide you with the applicable service for which we process that Personal Information.
- Legal Obligation. Where we are processing personal information based on a legal obligation, we generally will retain your personal information for the period of time necessary to fulfil the legal obligation.
- Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.
In all cases, in addition to the purposes, we consider the amount, nature and sensitivity of the Personal Information, as well as the potential risk of harm from unauthorized use or disclosure of your Personal Information.
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 firstname.lastname@example.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).
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 email@example.com.
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.
If you have any questions about this Privacy Notice or the Services, please contact us at:
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.
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 firstname.lastname@example.org to submit such a request.
- COLORADO, CONNECTICUT, UTAH, VIRGINIA
In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your personal information:
- Right of access. You may have the right to obtain:
- confirmation of whether, and where, we are processing your personal information;
- information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
- information about the categories of recipients with whom we may share your personal information; and
- a copy of the personal information we hold about you.
- Right of portability. You may have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
- Right to rectification or correction. You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you.
- Right to deletion or erasure. You may have the right, in some circumstances, to require us to delete erase your personal information.
- Right to restriction. You may have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- Right to opt-out. You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of “selling” or “share” your personal information with third parties in certain contexts.
- Right to withdraw consent. If you have provided consent for the processing of your personal information, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
- Right to appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.
To Exercise Your Right to Access, Right of Portability, Right to Correction, Right to Deletion, or Right to Appeal
Please submit a request by either:
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of Connecticut. In order to verify your identity, we will generally either require the successful authentication of your 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 rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
To Exercise Your Opt-Out Rights
Unless you have exercised your Right to Opt-Out, we may disclose or “sell” your 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 policies.
You do not need to create an account with us to exercise your Right to Opt-Out. However, we may ask you to provide additional personal information so that we can properly identify you 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 choose 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. We may not process your request if we, in good faith, believe that the request is fraudulent. In such instances, we will send a notice to the requestor explaining our decision.
To exercise the Right to Opt-Out of personal data “sales,” you may submit a request by clicking on the following link:
RIGHT TO OPT OUT