1.1. Scope

This Privacy Notice applies to all products, services, websites, and apps offered by Ideologix Insights, LLC’s dba Poll The Vote (“PTV”, also referred to as “we”, “us”, “our”), which are branded as “Poll The Vote” or “PTV” (collectively the “Service(s)”). Such services include, but are not limited to pollthevote.com, Poll The Vote platform, and Poll The Vote- or PTV-branded apps.

This Privacy Notice is for users located within the United States. This Privacy Notice outlines the type of Personal Data (defined below) that we collect and receive from and about you via the Services, and our data practices.

PTV’s Services are intended for users from the United States and those not governed by privacy policies of other countries. Users from the European Union (EU) are advised not to disclose your Personal Data to us. By providing your information and otherwise using our Services, you consent to the application of United States law to the use and disclosure of your information consistent with this Privacy Notice.

IF YOU DO NOT WISH US TO COLLECT, USE, AND SHARE INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE, PLEASE DO NOT USE ANY OF OUR SERVICES.

1.2. Changes

We may modify this Privacy Notice from time to time. If we make material changes to it, we will provide you notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. We agree that changes cannot be retroactive. If you object to any changes, you may deactivate your account through the Poll The Vote platform. Your continued use of our Services after we publish or send a notice about our changes to this Privacy Notice means that you consent to the updated version as of the effective date.

2.1. Why PTV Collects Personal Data

PTV is a nonpartisan social interest communication channel and network. We use demographic, psychographic, geographic, and other information provided by our registered consumer users (“Members”) to connect them with relevant elected officials and our other business clients (collectively, “Business Users”), political initiatives, and community interests.

2.2. What Do We Mean By ‘Personal Data’?

References in this Privacy Notice to personal information, data, or information, are all references to Personal Data. Personal Data means information relating to a living individual who is, or can be, reasonably identified from such information, either alone or in conjunction with other information.

2.3. Who Do We Collect Personal Data From?

PTV collects Personal Data from the following categories of users:

·       Business User: The elected official or other business client who holds an Organization Account within a PTV Service that either directly creates polls, forms, questionnaires, or other communications, or that can collaborate, comment, or review polls, forms, questionnaires, or other communications within an account.

·       Member: The individual user that receives polls, forms, questionnaires, other communications, or other recommendations powered by a PTV Service.

·       Visitor: The individual user who is just visiting one of our websites or other Services because you are curious or have heard about us from our marketing and sales channels.

2.4. Types of Personal Data We Collect

2.4.1. Registration Information

You need a PTV account before you can our Services. When you register for an account, we collect your first and last name, username, password, phone number, and email address(es). We also ask you to fill out a form providing us with certain additional Personal Data that we use to create your Member profile. We collect information such as date of birth, gender, employment status, household income, education level, marital status, household status, ethnicity, citizenship, political affiliation, state of voter registration, and so forth. 

2.4.2. Account Information

You can set various preferences and personal details through your account settings menu (or on your account settings page for our other Services as applicable). These may include, for example, your community settings (adding or removing yourself from community groups) and updating your Member profile information.

If you make a payment to PTV, we require you to provide your billing details, a name, address, email address and financial information corresponding to your selected method of payment (e.g., a credit card number and expiration date or a bank account number) through our third party payment processor. PTV does not store or process such financial information.

2.4.3. Cookie Information

First and third party HTTP cookies, IP addresses, browser user agent information, HTML cookies and/or Flash Local Shared Objects (Flash Cookies) may be used at various points of interaction to provide for a better user experience, to safeguard your Personal Data and to protect the integrity of the data collection process. These and other digital fingerprinting technologies are not used to collect data for any means other than the aforementioned reasons. Under no circumstances are these technologies used to prevent PTV members from deleting or removing cookies. Web and application server logs are used solely for security, support, troubleshooting and maintenance purposes. You can choose to remove or disable cookies via your browser settings.

2.4.4. Technical Support Information

PTV collects information submitted through our Tech Support emails, such as name, email, and message text. We also record the content of Tech Support and sales calls.

2.4.5. Usage Information

PTV collects usage information about you whenever you interact with our websites and other Services. This includes which webpages you visit, what you click on, when you perform those actions, what language preference you have, and so on.

2.4.6. Device And Browser Data

PTV collects information from the device and application you use to access our Services. Device data mainly means your IP address, operating system version, device type, device ID/MAC address, system and performance information, and browser type, and other device, network and browser signals. If you are on a mobile device we also collect the UUID for that device. We also infer your geographic location based on your IP address.

2.4.7. Event Data

PTV’s web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, device type and timestamps.

2.4.8. Integration Data

We collect information from third parties with whom PTV enables integrations in order to allow you to use both services.

2.4.9. Poll/Form/Questionnaire Data

We store your survey/form/questionnaire data (questions and responses) for you, provide analysis of this data, and provide analysis tools for you to use with respect to this data. We also learn from this data to provide more relevant poll invitations and recommendations.

2.4.10. Third Party Profile Data

We may combine information about you from third party sources (such as LinkedIn, ZoomInfo, and other data brokers) with information we hold about you to verify user information and/or provide more relevant poll invitations and recommendations.

Breaking down how PTV uses the information we collect is not simple because of the way the systems that provide our Services to you work. For example, the same piece of information may be used differently for different purposes to ultimately deliver a single Service. We think it’s most useful to describe the main ways we use information and if you have questions that are not answered, you can always email YourVoteCounts@PollTheVote.com.

3.1. Get Connected

The primary purpose of the PTV platform is to facilitate open communication between Members and elected officials and our other Business Users. We want our Members’ voices and opinions to be heard. On the organizational side, we want to help our Business Users collect meaningful analytics about their constituents and customers.

We use Personal Data about you (such as your address, legislative district, and other profile information) to identify relevant governance, public interest, and community connections, to provide you relevant polls, to inform you about relevant community and political information and events, and to enable other Members and Business Users to connect with you. Our Services also recommend community groups based on identified connections. You can opt in or out of recommended groups through your account settings menu.

3.2. Make Your Voice Heard

The information collected during the registration process and through your Member profile allows PTV to verify your eligibility, to determine which polls are appropriate for you, and to contact you regarding participation in polls.

We also use the information collected during registration and through your Member profile to provide you with a streamlined poll experience. For example, we use your profile information to eliminate the need for collecting repetitive demographic information in future polls.

We also use your information, including your poll responses, to optimize the polling experience for both the Member and the Business User. PTV may use first party machine learning or third party artificial intelligence tools on data around the type of survey the PTV or the Business User has sent you, the question type, poll responses (at an aggregated and de-identified/pseudonymized level only), and device and event data associated with responses to fulfill our contract with Business Users, and provide ourselves and our Business Users with useful and relevant insights from the data collected using our Services. Specifically, we use machine learning on poll data to help our Members and our Business Users by:

·       Identifying trends in responses;

·       Ongoing training of models to optimize responses;

·       Extracting and analyzing usage patterns, for example, identifying when respondents prefer multiple choice versus open-ended questions and make predictive response suggestions when certain question types are selected. We might also use this data to help improve analysis of responses;

·       Personalizing polls;

·       Improving Member experience (for example, by collecting and using device and browser information from respondents to improve how our survey Service operates on those devices and in those browsers, altering questions based on responses provided, or reducing or eliminating repetitive questions); and

·       Identifying insightful data trends (which do not disclose Personal Data) and make recommendations to Business Users based on those trends.

3.3. Operate, Improve, And Personalize Our Services

We use the information we collect to provide and operate PTV Services. We also use the information we collect to improve and personalize our Services so that you have a better experience on PTV, including by showing you more relevant content and connections, and inviting you to participate in more relevant polls. We may use the Personal Data and publicly available information to help train our machine learning or artificial intelligence models for the purposes outlined in this Privacy Notice.

We may use the information we collect from accounts of other services that you choose to connect your PTV account to provide you features like cross-posting or cross-service authentication, and to operate our services.

We use your Member profile information (without disclosing your Personal Data) to identify appropriate participants for polls and other research projects conducted by and/or on behalf of our Business Users.

We may use your information to provide our advertising and sponsored content services subject to your settings, which helps make ads on PTV more relevant to you. We also use this information to measure the effectiveness of ads and to help recognize your devices to serve you ads on and off of PTV. Some of our ad partners may also enable us to collect similar information directly from their website or app by integrating our advertising technology. Information shared by ad partners and affiliates or collected by PTV from the websites and apps of ad partners and affiliates may be combined with the other information you share with PTV and that PTV receives, generates, or infers about you, as described elsewhere in our Privacy Notice.

3.4. Make Our Services Safe And Secure

PTV uses the information we collect to provide for the safety and security of our users, our Services, and your account. This includes verifying your identity, authenticating your account, and defending against fraud, unauthorized use, and illegal activity. We also use the information to evaluate and affect the safety and quality of content on PTV – this includes investigating and enforcing our policies and Terms, as well as applicable laws and regulations.

3.5. Research, Troubleshoot, And Improve

PTV uses the information we collect to measure and analyze the effectiveness of our Services and to better understand how our Members and Business Users use them in order to make them better. We use information you share with us, or that we collect to conduct research, polls, product development, product testing, and troubleshooting to help us operate and improve our Services.

3.6. Communicate With You

PTV uses the information we collect to communicate with you about our Services, including about Service updates and changes to our policies and Terms. You may hear from us from time to time for business purposes such as to share updates, suggestions for maximizing your experience on the system, or marketing messaging.

3.7. Fulfill Our Legal Obligations

If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. We may also use usage data, event data, and aggregated or de-identified poll questions and responses:

·       To investigate security issues;

·       To prevent or address potentially unlawful activities;

·       To enforce our agreements where applicable; and

·       To screen for and prevent undesirable or abusive activity, for example, content that violates the Acceptable Uses in our Terms of Agreement.

4.1. Information You Share

Many of our Services let you share information with others. Remember that when you share information publicly, it can be indexable by search engines. Our Services provide you with different options on sharing and deactivating your content through your account settings menu, but we cannot delete content from search engines. Be careful about information you make public.

When you participate in polls, we disclose results in the aggregate to the Business Users of PTV who have requested such information. Our poll results only report aggregated and de-identified information. No Personal Data is provided to Business Users or third parties without the respondent’s prior “opt-in” consent.

For Organization Accounts, subject to your settings, some of your profile information will be visible to Members (e.g., your constituents or group members). We make contact information such as email and phone numbers available to Members to facilitate communication.

4.2. Information We Share

We do not share your information or data with third parties outside PTV except in the following limited circumstances:

4.2.1. Business Users of Organization Accounts

If you are a Business User that accesses the Services as part of an Organization Account, your account information and data will be shared with the primary administrator(s) of your account (e.g., the person(s) who pays for or manages the account), and your poll data may also be visible to other members of your account or with whom you collaborate. Your administrator(s) will be able to view your account data, change your passwords, suspend, transfer or terminate your account or restrict your settings. Please refer to your organization’s internal policies if you have questions about this. The primary administrator(s) does not have rights to your personal Member account.

4.2.2. Related Services

We will share your Personal Data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Notice to help our Services be more personalized, relevant, and useful to you and others.

4.2.3. Service Providers

We use others to help us provide our Services (e.g., maintenance, analytics, audit, payments, fraud detection, marketing, and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

4.2.4. Legal Disclosures

PTV may need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of PTV, our Members, Business Users, personnel or others. We attempt to notify Members and Business Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may, at our discretion, dispute such demands when we believe, in our discretion, that the requests are vague, overbroad, or lack proper authority, but we do not promise to challenge every demand.

4.2.5. Sale Or Change In Control

PTV can also share your personal data as part of a sale, merger, or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Notice.

5.1. Data Retention

We generally retain your Personal Data as long as you keep your account open or as needed to provide our Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services only infrequently, we will generally retain your information and keep your account open, unless you deactivate your account. In some cases, we choose to retain certain information (e.g., poll responses, insights about Services use, etc.) in a depersonalized or aggregated form, even after you deactivate your account.

5.2. Your Rights

We provide many choices about the collection, use and sharing of your data. We offer you settings to control and manage the personal data we have about you. For Business Users, these choices must be made by the primary administrator(s) of the Organization Account.

For Personal Data that we have collected about you, you may have the right to:

·       Delete Data: You can ask us to delete or erase all or some of your Personal Data (e.g., if it is no longer necessary to provide Services to you). Please note, however, that deletion of your Personal Data may not extend to data we have already sent to Business Users or other third parties, aggregated data, or data we keep for backup/archiving and legal compliance purposes

·       Change or Correct Data: You can edit some of your Personal Data through your account settings menu. You can also ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.

·       Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your Personal Data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

·       Right to Access Your Data: You can ask us for a copy of your Personal Data and can ask for a copy of Personal Data you provided in machine readable form.

You can contact us at YourVoteCounts@PollTheVote.com to make these requests, and we will consider your request in accordance with applicable law.

5.3. Who Is Your Data Controller?

If you have provided poll responses, filled out a form, filled out a questionnaire, or provided feedback to a Business User using PTV’s services, that Business User is the controller of your data, and PTV is the processor of that data.

If you have provided poll responses, filled out a form, filled out a questionnaire, or provided feedback directly to PTV, then PTV is the controller and our use of that data. PTV is a controller for the account-level (e.g., profile data, contact information, etc.) data provided by Members and Business Users.

When PTV is acting as a processor of poll response data on behalf of its Business Users, we do not control the responses collected and cannot directly handle Member requests for editing, deleting, or providing a copy of responses. We will help Members get in contact directly with the primary administrator of the Organization Account, and we will help primary administrators comply with such Member requests. Member rights to edit or delete data may not apply to aggregated response data.

5.4. Account Deactivation

If you choose to deactivate your PTV account, your Personal Data will generally stop being visible to others on our Services within 24 hours. We may retain certain Personal Data and aggregated information as set forth below.

We retain your Personal Data even after you have deactivated your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Acceptable Use Terms), enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We may retain de-personalized information and/or aggregated information after your account has been deactivated.

Information you have shared with others (e.g., through email or group communications) will remain visible after you deactivate your account or delete the information from your own profile, and we do not control data that other Members or Business Users have copied out of our Services. We cannot delete aggregated information (e.g., poll results) that has lawfully been provided to our Business Users in accordance with this Privacy Notice. If you have opted to provide Personal Data (e.g., personalized or identifiable information) directly to Business User(s), we may not be able to delete such data. Your information may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

6.1. Security

PTV implements security safeguards designed to protect your Personal Data, such as encryption and two-factor authentication, that meet or exceed industry standards. We regularly monitor our systems for possible attacks and vulnerabilities. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. 

6.2. Children’s Privacy

The Services are not for use by anyone under the age of 15 (the “Minimum Age”). If you are under the age of eighteen (18) (or the legal age of majority in your jurisdiction), you represent by accessing Services that you have your parent’s or legal guardian’s approval to access them, and your Personal Data and poll responses shall be used for the same purposes and shall be subject to the same obligations, restrictions and conditions as any other Member.

PTV complies with all applicable provisions of the Children’s Online Privacy Protection Act of 1998 (COPPA). If it comes to our attention that we have collected Personal Data from a user under the Minimum Age, we may delete this information without notice. If you have reason to believe that this has occurred, please contact at YourVoteCounts@PollTheVote.com.

6.3. Direct Marketing

We currently do not share personal data with third parties for their direct marketing purposes. 

6.4. Cross-Border Data Transfers

We currently process data only inside of the United States and do not transfer data across borders. 

6.5. General

By visiting the pollthevote.com website or otherwise accessing the Services, you agree that this Privacy Notice and the Terms of Agreement  govern your use of the Services. All disputes over privacy shall be governed as set forth in this Privacy Notice or in the Terms of Agreement, including applicable law, arbitration rules and limitations on damages. You should review pollthevote.com website periodically for any changes to this Privacy Notice and the Terms of Agreement.

6.6. Contact PTV

If you have questions or concerns about this Privacy Notice, you may contact PTV at YourVoteCounts@PollTheVote.com. For legal notices or service of process, you may write us at the following address:

Ideologix Insights, LLC

1737 South 173rd Plaza

Omaha, NE 68130