September 1, 2023

1. INTRODUCTION

1. PURPOSE OF THIS POLICY. 

Million Voices, an Association of Churches, and its affiliates, as applicable (hereafter, “us,” “we,” “our” or “Ministry”), provides educational resources, conducts surveys, and provides other various services for the purpose of raising awareness of issues affecting culture and equipping users to engage civically as agents of change for the good of their communities and of the nation as a whole. (Our website, together with our online platforms and mobile applications, including their features, products and services, are individually and collectively referred to as, the “Site”). 

1.  OUR COMMITMENT.

The Ministry respects the privacy rights of users of our Site. We are committed to transparency about data we hold and have designed this policy (“Privacy Policy”) to help you understand the types of information we collect, how it is used, with whom it is shared, and the choices you have regarding the storage, deletion, transfer, and disclosure of personal information relating to you. 

1.   SCOPE. 

This Privacy Policy answers the following questions:

• What information do we collect about you and how do we collect it?
• How do we use your personal information, and do we share it with others?
• What choices do you have about the collection and use of your personal information?
• What security measures do we take to safeguard your personal information?

2. INFORMATION COLLECTION PRACTICES

2.1.  WHAT INFORMATION DO WE COLLECT?

(a) PERSONAL INFORMATION.  In operating the Site, we collect information that can be used to identify or contact the user (“Personal Information”), which includes information that falls within some or all of the following categories:

1. Identifiers, such as a user’s first and last name, e-mail address, mailing address, shipping address, zip code, phone number, geolocational information, voice, photograph, signature, electronic signature or other likeness; 
2. Account Information, such as a username, password, and password reminder questions and answers; 
3. Characteristics of Protected Classifications and other Demographic Information, such as age, gender, ethnicity, religious preference, marital status, and date of birth;
4. Commercial Information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
5. Inferences Drawn from Personal Information, such as those reflecting preferences, characteristics, psychological trends, predispositions, behavior, or attitudes;
6. Internet or Other Electronic Network Activity, including IP addresses, device information, information regarding interactions with an Internet website, application, or advertisement, such as browsing history within the Site, including access times, length of use, and search history; and
7. Financial Information, such as credit or debit card information, annual income, and identity verification information. 

(b) ADDITIONAL INFORMATION

1. Survey Data, such as information, feedback, or content you choose to provide when you participate in a survey conducted by us or another organization;
2. Traffic Data, defined as anonymous “traffic data” that does not personally identify you, but which may be helpful for marketing purposes or for improving your experience on the Site; and
3. Cookies, providing information that allows us to recognize your browser and store a small piece of data on your computer or device about your visit to our Site. We do not set any personally identifiable information in cookies. (For information on how this information is used, please refer to Section 3.3(c) below. If you do not wish to accept cookies, you may change the setting on your browser.  However, if you choose to disable this function, your experience at the Site may be diminished, and some features may not work as they were intended. For instance, without cookies you may not be able to receive information or resources that are specifically relevant to you.)  

2.2.  HOW DO WE COLLECT THE INFORMATION?

1. Your use of the Site:

1. In operating the Site, we may request or invite user registration and logins, invite participation in online surveys, and provide various other online forms that invite users to provide certain Personal Information.  
2. If you communicate with us by e-mail or other means, any Personal Information provided in such communications, including attachments, may be collected by us.  
3. Our servers automatically collect certain types of Personal Information relating to your interactions with the Site. 

1. Third-Party Sources: 

1. In accordance with applicable law, we collect Personal Information from publicly available sources, including, but not limited to, government agencies; for example, we may collect Personal Information from voter files. 
2. We also collect data from business partners and affiliates who may provide us with your Personal Information; for example, we may collect Personal Information from surveys conducted by business partners.

3. USE AND SHARING OF COLLECTED INFORMATION

3.1. HOW DO WE USE YOUR PERSONAL INFORMATION? 

(a) BUSINESS AND COMMERCIAL PURPOSES. We may use your Personal Information for certain business and commercial purposes, including, but not limited to:

1. Auditing related to current interaction and concurrent transactions to enable us to customize and tailor your experience by delivering targeted resources and other content specific to your interests.
2. Analyzing and creating data sets by combining the Personal Information we collect about you.
3. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
4. Debugging to identify and repair errors that impair existing intended functionality.
5. Maintaining or servicing accounts, carrying out our obligations to you, processing donations or other transactions, verifying your information, communicating offers or information by our affiliates and other third parties, providing resources, services or content you request, answering your questions, and facilitating various other services or communications.
6. Undertaking internal research for technological development and demonstration.
7. Undertaking activities to verify or maintain the quality of a service provided, and to improve, upgrade, or enhance our services.
8. Serving purposes otherwise permitted by applicable law.

(b) ON OUR SITE.  We may display your Personal Information in your profile page and elsewhere on the Site according to the preferences you set in your account.  Any information you choose to provide should reflect how much you want others to know about you.  Please consider carefully what information you disclose in your profile page and your desired level of anonymity.  We may also share or disclose your information if, for example, you use a third-party application to access your account.  Through certain features of the Site, you may also have the ability to make some of your information public.  Public information may be broadly and quickly disseminated.

(c) In addition, we may use your Personal Information in the following ways: 

(1) Significant Announcements. If you are a registered user of the Site, we may use your registered name and address or e-mail address information to inform you via mail or e-mail message of any significant changes to the Site or the Ministry, to any user account you may create, or other significant information that may affect your use of the Site. We may also communicate with you about privacy, security or administrative issues relating to your use of the Site. You cannot opt out of these kinds of e-mail messages. 

(2) Mobile Communications. If you choose to opt in, we may also use your mobile phone number information that you provide on the Site to send you information about various promotions and other types of offers from us. Any text messaging originator opt-in data and consent will not be shared with any third parties. 

(3) Push Communications. If you choose to opt in, we may also use browser notifications to send you information about various promotions and other types of offers from us. 

If you do not wish to receive these kinds of communications from us, you can opt out by un-checking the appropriate email announcement boxes during registration, by changing your user account, or by emailing us at the address provided in this Privacy Policy. In addition, you will have regular opportunities to opt out of receiving such information from us by following the unsubscribe instructions in email messages or mobile communications we may send to you. 

3.2.  DISCLOSURE OF PERSONAL INFORMATION TO OTHERS

1. NO SALE OF PERSONAL INFORMATION. The Ministry does not sell your Personal Information.

1. PROCESSING. We may use an outside credit card company or payment processor to process donations or payments for services, and other business partners to perform core services (such as, for example, hosting, data storage, or security) related to our operation of the Site. We authorize these third parties to only access and use your Personal Information to perform their functions.

1. PRODUCTS AND SERVICES. The Ministry may partner with other third parties to provide specific products and services on the Site. When you sign up for such products or services, we will share only the Personal Information that is necessary for the third party to provide these products or services. We do not authorize the third party to use Personal Information except for the purpose related to these products or services. 

1. OTHER BUSINESS AND COMMERCIAL PURPOSES. The Ministry may disclose Personal Information to third parties as reasonably necessary to accomplish the business and commercial purposes set forth in section 3.1(a) above. 

1. LEGAL PURPOSES. We may disclose Personal Information and information concerning your use of the Site if required to do so by law or in the good-faith belief that such action is necessary (1) to conform to the edicts of the law or comply with legal process served on us or our parent entity, subsidiaries or affiliates (for example, pursuant to a statutory demand, subpoena, warrant or court order), (2) to protect and defend the rights or property of the Ministry or the users of the Site, (3) to protect against fraudulent, abusive or unlawful use of the Site, (4) to enforce any contract between you and the Ministry, or (5) to act under what the Ministry reasonably believes to be exigent circumstances to protect the safety of the public or users of the Site.

1. BUSINESS TRANSFERS. In order to accommodate changes in our business, we may merge with companies, or sell or buy companies or assets of companies, including the information collected through the Site. Upon acquisition of the Ministry, a line of business of the Ministry, or substantially all the assets of the Ministry, customer information will be one of the assets transferred to the acquirer. The Ministry reserves the right to disclose and transfer all information collected through the Site: (1) to a subsequent owner, co-owner or operator of the Site or applicable database; or (2) in connection with a corporate merger, consolidation, restructuring, the sale of certain of Ministry ownership interests, assets, or both, or other  change, including, without limitation, during the course of any due diligence process. In addition, the Ministry may share the information collected through the Site with its parent entity, subsidiaries, and affiliates, primarily for business and operational purposes.  Should such an event occur, the Ministry will use reasonable means to notify you through a prominent notice on the Site.  By sharing your Personal Information with the Ministry, you are giving the Ministry consent to transfer your Personal Information to a third party in an asset transfer described here. 

3.3 WHAT DO WE DO WITH OTHER COLLECTED INFORMATION?

(a) ANONYMOUS INFORMATION. We use anonymous information to analyze our Site traffic and usage information, record transactions, and gather demographic information, but we do not examine this information for individually identifying information. In addition, we may use anonymous IP addresses and unique identifiers to help diagnose problems with our server, to administer the Site, or to display content according to your preferences. 

(b) DE-PERSONALIZATION.  We may make your Personal Information non-personally identifiable by either combining it with information about other users (aggregating your Personal Information with information about other users), or by removing characteristics (such as your name, signature, electronic signature, address or email address) that make the information personally identifiable.  This process is known as de-personalizing your information.  You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your Personal Information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect on the Site.  

(c) COOKIES. We may use cookies to: (1) deliver content specific to your interests; (2) save your password so you don’t have to re-enter it each time you visit the Site; (3) help us remember and process requests; (4) measure the effectiveness of the Site and our various resources and services; (5) keep track of campaigns; (6) improve navigation and other features of the Site; (7) promote trust and safety on the Site; or (8) provide features and services that are available only through the use of cookies. 

(d) “DO NOT TRACK” SIGNALS.  Because we do not collect user information about your online activities over time and across different websites or authorize third parties to do so, we do not respond to “Do Not Track” signals.

4. SECURITY

4.1. HANDLING OF DATA. 

The Personal Information you provide to us is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure the security of such information.  In addition, the Ministry employees and agents who have access to your Personal Information are trained in the maintenance and security of that information.  However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure.  As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the Site and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk.  Once we receive a transmission from you, we will endeavor to maintain its security on our systems.

4.2. LOST OR STOLEN INFORMATION.  

If you lose control of your password, you may lose substantial control over your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised in any way, you should immediately change your password.

4.3. NO REQUIREMENT TO PROVIDE INFORMATION TO USE THE SITE. 

You acknowledge and agree that any information or content that you post to the Site is public, not private, and that you have no expectation of privacy with regard to such information and content. If you choose to make any of your personally identifiable or other information publicly available through or in connection with your use of the Site, you do so at your own risk. Because any information that you post to the Site may be seen and used by others, the Ministry encourages you not to disclose any personally identifiable information through your posts to the Site. 

5. CALIFORNIA PRIVACY RIGHTS 

5.1. If you are a resident of California, the California Consumer Privacy Protection Act (“CCPA”) provides you with certain rights regarding your Personal Information.

(a) REQUEST FOR DISCLOSURE REGARDING PERSONAL INFORMATION.  You have the right to request and receive the following information, for the 12 months preceding the request: 

1. the categories of Personal Information, as defined by the CCPA and set forth above in section 2.1.(a)(1)-(7), that we collect;
2. the categories of Personal Information, as defined by the CCPA and set forth above in section 2.1.(a)(1)-(7), that we share for a business purpose;
3. the categories of sources, as set forth above in section 2.2., from which the Personal Information has been collected; 
4. the business or commercial purposes, as set forth above in section 3.1.(a), for collecting and/or selling the Personal Information;
5. the categories of third parties, as set forth above in section 3.2., to whom the Personal Information (by individual category of information) was shared or sold;
6. the specific pieces of Personal Information collected; and
7. the specific third parties who received the Personal Information.

(b) CORRECTION, UPDATE, AND DELETION OF PERSONAL INFORMATION. We maintain a procedure in order to help you confirm that your Personal Information remains correct and up to date. Following registration, you can sign in to your user account and visit your personal profile page, where you can deactivate your user account, or review and update your personalized preferences and registration information, such as: name, mailing address, shipping address, e-mail address, password, and e-mail notification settings and preferences.  (In addition, many of the mailings the Ministry may send you, such as newsletters, contain an “unsubscribe” feature to allow you to opt out of future mailings.)   

You may also request that we correct, update or remove Personal Information from our database. Upon request, we will remove the Personal Information and direct our service providers to remove the same from their records.  We may retain in our files information you have requested be removed from our active databases for certain purposes, such as to resolve disputes, troubleshoot problems and enforce our terms and conditions. Further, such prior information may never be completely removed from our databases due to technical and legal constraints, including stored “back up” systems. Therefore, you should not expect that all of your Personal Information to be completely removed from our databases in response to any request you may submit. 

(c) RIGHT TO NON-DISCRIMINATION.  We do not discriminate against you for exercising any of your privacy rights under the CCPA or applicable law, including discrimination in the form of:  denying you goods or services; charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing you a different level or quality of goods or services; or suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services. 

5.2. EXERCISING YOUR CCPA RIGHTS.  To exercise the rights described above, please submit a request to us via email at info@keydigitalstrategies.com   

6. CONTACT INFORMATION AND POLICY UPDATES
   
   

6.1. CONTACT US. 

If you have any questions about this Policy, questions about our practices related to this Site, or if you would like to exercise your CCPA rights, please contact us via email at info@keydigitalstrategies.com  

6.2. POLICY UPDATES AND CHANGES. 

If we decide, at any time, to add to, change, update, or modify this Policy, we will post such change, update, or modification on this page and update the “Effective Date.” Any such change, update, or modification will be effective immediately upon posting the updated Policy. We will notify you of any material changes to the Policy by placing a notice on the Site or sending a notice to the primary email address specified in your user account. It is your responsibility to review this Policy when visiting the Site to ensure that you continue to agree with all of its terms.  If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Site.

7. VISITORS FROM OUTSIDE THE UNITED STATES|
   
   

Our offices are located in the United States. If you visit the Site from another country, please be aware that information you provide to us or that we obtain as a result of your use of the Site may be processed in and transferred to the United States and will be subject to U.S. law. U.S. privacy and data protection laws may not be equivalent to the laws in your country of residence. By using the Site, you consent to the collection, transfer, storage, and processing of information to and in the United States.

8. GOVERNING LAW
   
   

This Privacy Statement is governed by, and construed under, the laws of the United States of America and the laws of the State of Texas, excluding its choice of law provisions.

Mediation. You agree that, in the event any dispute or claim arises out of or relating to this Privacy Statement, you and the Ministry will attempt in good faith to negotiate a written resolution of the matter directly between the parties.  You agree that if the matter remains unresolved for forty-five (45) days after notification (via certified mail or personal delivery) that a dispute exists, all parties shall join in mediation services in Tarrant County, Texas with a mutually agreed mediator in an attempt to resolve the dispute.  Should you file any arbitration claims, or any administrative or legal actions without first having attempted to resolve the matter by mediation, then you agree that you will not be entitled to recover attorneys’ fees, even if you would otherwise be entitled to them.

9. 9. TERMS OF USE
   
   

Please read the Terms of Use governing the use of the Site.