Privacy Policy
Effective as of October 10, 2023, this is the privacy policy of Pinion (referred to as Pinion, PinionVote, “we”, “us” or “our” in this privacy policy). This privacy policy will inform you as to how we handle your personal data when you visit our website and tell you about your privacy rights.
IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
Pinion (PinionVote) was founded in 2018 as a non-profit advocacy group focused on democracy. Our first priority is you, our community of voters and democracy advocates. We believe in our providing the right information to help you succeed and hold ourselves to the highest standards.
1.1 PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how Pinion collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to register/ join, register for an event, conference or webinar, sign up for our newsletter, and/or sign up for any other activity through our website. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them. For example, if you register for an event, this privacy policy supplements any notice you may receive in connection with that registration.
1.2 CONTROLLER
Pinion is the controller and responsible for your personal data. We have appointed a Privacy Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Privacy Officer using the details set out below.
1.3 CONTACT DETAILS
Privacy Officer – David S Slight
Address – 3865 Cliffside Drive, Bellingham, WA 98225, USA
Email – Privacy.Officer@pinionvote.com
Phone & Voicemail +1 (425) 623 4810
PinionX SPC - Business registration number 604981758
In the event of a dispute, you may have the right to make a complaint with your local authorities. We would, however, appreciate the chance to deal with your concerns first because your privacy is important to us.
1.4 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
This version of the policy was last updated on the effective date first set forth above. Historic versions can be obtained by contacting our Privacy Officer. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, if applicable.
1.5 THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and/or applications, including those of our affiliates. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which may include the following categories follows:
- Identity Data includes first name, last name, username or similar identifier, gender, responsibility level, title, and certification status.
- Contact Data includes home address, billing address, delivery address, email address and telephone numbers.
- Transaction Data includes details about services you have obtained from us, including registrations and credit card information.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, registrations, and sign-ups by You.
- Usage Data includes information about how you use our website and services. Usage Data may include information such as Your Device’s Internet Protocol address (IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
- Marketing and Communications Data includes Your preferences in receiving marketing from us and Your communication preferences (including as to the Mailing List).
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and bio-metric data). Nor do we collect any information about criminal convictions and offenses. Do not share any Special Categories of Personal Data with us.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to allow you to register for an event). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED
We use different methods to collect data from and about you including through:
- Direct interactions
You may give us your Identity and Contact Data by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes personal data you provide when you:- register for an event, etc.
- create an account on our website
- leave a comment on our website
- subscribe to our newsletter, or
- give us some feedback (when you Contact Us).
- Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. - Third parties or publicly available sources
We do not collect information about you from third parties.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data in order to carry out our mission as a social purpose corporation. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you, such as our obligations to you in connection with your rights as to events, for example.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you give us your consent to send you Pinion communications.
Generally, we do not rely on consent as a legal basis for processing your personal data because we do not send third party marketing communications. In any event, if we send you any communications, you will have the opportunity to Opt-Out.
4.1 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Examples of how we use your personal data include:
- To personalize your experience on our website, as a member or potential member. Your information assists us to better respond to your individual needs.
- To improve the website. We continually strive to improve our website offerings based on the information and feedback we receive from you.
- To improve customer service. Your information helps us to more effectively respond to your customer service requests and support needs. Customer service is available to support membership enrollment or changes, registering for events, etc.
- To provide the aggregated information when recording support and importance scores on specific legislation.
- To communicate with volunteers who have applied to volunteer on Pinion committees or working groups.
- To include registrants in conference related materials, information on future events, offer specials on registration fees and to utilize survey feedback data to help improve our events.
- To process transactions. Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
- To conduct an election for the Pinion Board of Directors. All active Pinion members in good standing are invited to participate in the election of Pinion’s Board of Directors.
- To administer a promotion, survey or other site features.
- To send periodic emails and electronic messages. The email address or other electronic addresses you provide for order processing may be used to send you information and updates pertaining to your order, in addition to receiving occasional organization news, updates, related product or service information, etc.
- For community leaders to access the profile information of chapter members, if applicable, to be able to contact you.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the Privacy Officer if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/ Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new member | (a)Identity (b)Contact | Performance of a contract with you |
| To process and deliver your membership activities (events, certifications, newsletter, etc.), including but not limited to: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Transaction (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include notifying you about changes to our policies or terms of service | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our operations and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our operation, provision of administration and IT services, network security, to prevent fraud etc.) (b) Necessary to comply with a legal obligation |
| To use data analytics to improve our website and visitor experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to keep our website updated and relevant) |
4.2 PROCESSING PROVIDERS
Below is a table of third-party data processors currently used by Pinion. THis table was last updated 2/18/2024:
| Processor Name | Processing Activities | Data Location(s) |
|---|---|---|
| AdButler Digital | Advertising Provider | United States |
| Amazon Web Services, Inc. | Cloud Service Provider | United States |
| Base CRM | Contract Management | United States |
| Google Analytics | Usage Analytics Data Provider (see Google Cloud Platform Subprocessors for further information) | United States |
| Google Drive | Cloud Service Provider | United States |
| MailChimp | Bulk Email Provider | United States |
| Microsoft 365 | Cloud Service Provider | United States |
| Monday.com | Contact and Contract Management including “personal data, and certain types of User Data” see monday.com | United States |
| Quickbooks, Inc. | Accounting Software Provider | United States |
| Stripe, Inc. | Payments Gateway Processor | United States |
| Survey Monkey | Survey Platform | United States |
4.3 MARKETING
All marketing is done in connection with the membership services (events, training, access to content, etc.) and each individual will have the opportunity to Opt-Out from such marketing.
4.4 THIRD-PARTY MARKETING
Although currently no third-parties are used for marketing purposes, if this policy should change we will get your express opt-in consent before we share your personal data with any company outside Pinion for marketing purposes.
4.5 OPTING OUT & CHOICES
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes in your profile under “Manage Profile” to adjust your communication preferences or by following the opt-out links on any message sent to you or by contacting the Privacy Officer. Please allow a reasonable time for us to respond to your request. In addition, you may unsubscribe by logging into your profile and click “Yes” under the Pinion Communications Options. Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of your status as a member, or a registrant for an event or other transactions. You have many choices about your data, including:
- You can update and correct most of your personal data through your account. If this is not possible, you can ask us to update your data, particularly in cases of inaccuracy, by contacting the Privacy Officer.
- You can opt-out of email communications in your Pinion profile, or by contacting by contacting the Privacy Officer for assistance in doing so.
- You may also revoke your consent to processing and ask us to delete your data.
- You may determine whether certain information about you will be visible to others by navigating to “Edit Bio” in the “Manage Profile” area on our website and editing the visibility settings of your information.
4.6 COOKIES
A cookie is a small text or data file that can be stored on your computer when you visit websites. Information is saved in this text file to ensure a smooth and interactive experience on the internet. Cookies usually also have an expiration date. For example, some cookies are automatically deleted when you close your browser (so-called session cookies), while others can be stored longer on your computer, sometimes until you delete them manually (so-called permanent cookies). You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.4.7 CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Privacy Officer.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data for the purposes set out in the table in Paragraph 4 above, as follows:
Service providers, acting as processors, based in the United States who provide IT, payment processing, web hosting, web design, conference app hosting, elections, surveys, webinars, and system administration services.
Professional advisers, acting as processors or joint controllers, including lawyers, auditors and insurers based in the United States who provide consultancy, legal, and insurance services.
State and federal government agencies, regulators and other authorities, who may require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes.
Transfer of your personal data.
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred.
We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By law we may have to keep basic information about our members (including contact, identity, and transaction data) for up to seven years after they cease being members (for tax purposes.) In some circumstances, you can ask us to delete your data: see Request erasure below for further information.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact our Privacy Officer.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our Privacy Officer. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
You have the right to:
Request access
to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time
where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
CONTACTING PINION
If there are any questions regarding this Privacy Policy you may contact us using the information below.
CONTACT DETAILS (repeated as above in 1.3)
Privacy Officer – David S Slight
Address – 3865 Cliffside Drive, Bellingham, WA 98225, USA
Email – Privacy.Officer@pinionvote.com
Phone & Voicemail +1 (425) 623 4810
PinionX SPC - Business registration number 604981758