Privacy Policy

Last modified: June 30, 2023

Introduction

MissionWired, a trade name of Anne Lewis Strategies, LLC (“MissionWired” or “We” or “Us” or “Our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from or through our website https://missionwired.com (our “Website”), services, products, databases, and tools (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to the information collected from and provided to customers as part of our digital co-op services (“Co-op Information”), information collected from our customers so that they can use our Services (“Customer Information”), and information collected from our Website, including visitors who browse the Website and/or submit information via the Website (“Website Information”).

This policy does not apply to information that we collect from our employees and contractors.  This policy also does not apply to information we handle solely in our capacity as a service provider on behalf of a customer (“Service Provider Information”).  Service Provider Information includes information processed on behalf of customers that engage us for us consultancy services and are subject to our agreements with such customers.  Service Provider Information is subject to the privacy policies of the customer, and you should read those policies carefully.  We are not responsible for the privacy practices of our customers.  If you have any questions about a customer’s privacy practices, please contact the applicable customer.  For more information about who is the controller of data and under what circumstances, refer to the “Your Choices and Rights” section below.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you are a Website visitor and/or customer and you do not agree with our policies and practices, please do not use and/or visit the Services. Additional information about your opt-out choices is detailed in the “Your Rights and Choices” section below.

Information We Collect About You and How We Collect It

 


We obtain information about you through the means discussed below.

Co-op Information

Our “Digital Co-op” is a data sharing group comprised of our customers (“Co-op Members”), including non-profits and political organizations, who share data for the collective benefit of such Members including to develop new supporters, reactivate lapsed supporters, improve their outreach, and other similar purposes.  The Co-op Members that participate in our Digital Co-op are the entities that collect information from or about you.  Co-op Members may provide us your name, email address, phone number, mailing address, and information about your interactions with a particular Co-op Member, including donation activity.

Customer Information

When Customers sign up to use the Services, we collect information in order to provide these Customers with our Services, including personal contact information regarding Customers’ end users (e.g., their employees) of the Services and financial information for billing purposes.

Website Information

Website Information Collected from Website Visitors.  When you visit our Website, we may automatically receive and store certain information about you through your device(s).  As discussed further below, we and our service providers (which are other companies that work on our behalf), may use a variety of technologies, including cookies, to assist in this collection.

  • Device Information. We collect technical information associated with the device(s) you use to visit our Website, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, and other information such as your device type.
  • Usage Information. We also collect a variety of information to better understand use of our Website. This may include the webpage that you were visiting before accessing our Services, the pages or features of our Website you use, how much time you spend there, date and time of use, and information about your usage preferences.

Website Information Provided by You.  We also may collect information that you directly provide to us on our Website.  For example, we may collect information about you when you submit an inquiry about our services, such as your name, contact information, and the subject of your inquiry.

Information Collected from Third Party Sources (Other than Co-op Members)

We may also collect information about you from third parties who license, sell, or otherwise provide data they have collected.  This information may be combined with the categories of information listed above.  For example, if we collect Co-op Information about you, we may also collect information from third party sources like your name, email address, mailing address, phone number, voter registration details, and information about your online interactions and email engagement activity.

If you are a current or prospective Customer and we collect Customer Information and/or Website Information from or about you as described above, we may also collect certain information about you like your name, business email address, business mailing address, or business phone number from third party sources. Any references to Co-op Information, Customer Information, and/or Website Information below in this policy include such information obtained from third parties.

Cookies and Similar Technologies

To collect the information described in the “Website Information Collected from Website Visitors” section above, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, and similar tracking technologies.  We use these technologies in order to offer you a more tailored experience in the future.

  • A web server log is a file where online activity is stored.
  • An SDK is a set of tools and/or code that we embed in our applications and software to perform certain functions, such as allowing us or third parties to collect information about how you interact with the Services.
  • A cookie is a small file placed on your computer or mobile device when you use the Services that enables us to: : (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages you have visited on our Services and elsewhere; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
  • Tags or tracking pixels (sometimes also referred to as web beacons or clear GIFs) are small code (sometimes containing, generating, or detecting a unique identifier) embedded in websites, online ads, and email that can be used for purposes such as generating web server log or reading or writing cookies for the purposes described above.

As we adopt additional technologies, we may also gather information through other methods.

You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting, you may be unable to access certain parts of our Website.

Online Analytics and Advertising

Online Analytics

We may use analytics services on our Services to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to our customers.

Online Advertising

We may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google’s ad services, and others) on our Website that use cookies and similar technologies to deliver relevant and targeted content and advertising to you about the Services on other websites you visit and applications you use.  The ads may be based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic data, and other information we collect about you.  These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

We sometimes also associate cookies with data linked to or derived from data you have submitted to us (e.g., your email address) and disclose such information to advertising partners and vendors in hashed, non-human-readable form to provide you with more relevant ads when you visit other websites and mobile applications.

The use of cookies or other tracking technologies that may be placed on devices you use to access our Website by non-affiliated third parties is governed by the privacy policies of those third parties.  If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.  To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page.

For additional ways to opt out of targeted advertising activities under applicable law, see the “Your Rights and Choices” section below.

Please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Website.

Notice Concerning Do Not Track

Do Not Track (“DNT”) is a privacy preference that is available in certain web browsers.  We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, which is why we describe a variety of opt-out mechanisms above.  However, we do not currently recognize or respond to browser-initiated DNT signals.  Please note that Do Not Track is a different privacy mechanism than the Global Privacy Control signal referenced in the “California Privacy Notice at Collection” section below, which is a browser-based control that indicates whether you would like to opt out of processing of your information for certain purposes, such as the “sale” of your information or the disclosure of your information for targeted advertising purposes.

How We Use Your Information


Co-op Information

We use the Co-op Information to provide, support, and develop our Services.  In particular, we may use this information to:

  • Provide our Services. We may use the Co-op Information to provide our Co-Op Members with our Services.
  • Operate our Services. We also may use the Co-op Information for our own internal purposes in accordance with applicable contractual obligations, such as to improve, test, update and verify our own database; develop new products; operate, analyze, improve and secure our Services and our databases and servers.
  • Other Internal Purposes. We may use the Co-op Information to comply with any procedures, laws, and regulations where necessary for our legitimate interests or legitimate interests of others; and establish, exercise, or defend our legal rights where necessary for our legitimate interests or the legitimate interests of others, including the enforcement of our terms, other usage policies, and other legal terms or controls, or to engage in other legal matters.

Customer Information and Website Information

We use Customer Information and Website Information for the follow purposes:

  • To create and manage your unique customer account.
  • To provide the Services to you.
  • To present our Website and its contents to you.
  • To provide you with information that you request from us.
  • Send you offers and ads for our Services when you browse the Website or other companies’ websites on the Internet (such as to “retarget” you with information about our Services).
  • If we collect from “offline” sources – such as if you provide us your business card – we will maintain that information and use it for marketing and business purposes, as well.
  • To send you offers and ads for products and services of partner brands, or other offers we believe may be of interest to you, such as invitations to events and webinars.
  • To perform data analysis (including market research).
  • We may use IP addresses to help diagnose problems with our servers, to administer our Website, to help identify visitors to our Website for the duration of a session, and to gather demographic information about our visitors.
  • We may use clickstream data to determine how much time visitors spend on each web page of our website(s), how visitors navigate through the website(s), and how we may tailor our website(s) to better meet the needs of our visitors.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

Combine Information. For the purposes discussed in this policy, we may combine the information that we collect through the Services with information we receive from other sources, both online and offline, and use such combined information in accordance with this policy.

Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data with any third parties in our discretion.

Disclosure of Your Information


Co-op Information

We may disclose Co-op Information as described below:

  • Co-op Members. We may disclose your information with the Co-op Members, including political and non-profit organizations.
  • Subsidiaries and Affiliates. We may disclose your information to our subsidiaries and affiliates.
  • Corporate Transactions. We may disclose information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
  • Service Providers. We may disclose information collected with select vendors who use the information to provide services on our behalf, such as Services operation, surveys, web hosting, marketing and sales, billing and payments processing, analytics and online advertising, security, fraud prevention, and legal services.
  • For Legal Purposes. We reserve the right to disclose information to third parties when we, in good faith, believe that such access or disclosure is reasonably necessary to comply with the law, regulation, legal process or a governmental request. We may also disclose your information to enforce our terms; to detect, prevent, or otherwise address fraud, security, or technical issues; to respond to user support requests; and to protect the rights, property or safety of MissionWired, our customers, and the public.
  • At Your Direction. We may disclose information with third parties when you direct us to do so.

Website and Customer Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To vendors we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. For any other purpose disclosed by us when you provide the information.
  • With your consent.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  The safety and security of your information also depends on you.  Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to us through the Website.  Any transmission of information through the Website is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

You may be prompted to create a username and password in order to access certain features of the Services.  You are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account.  We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password.  We urge you to change your passwords often, use a combination of letters and numbers, and make sure you are using a secure browser.  If you have reason to believe that your interaction with us is no longer secure or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “Contact Information” section below.

Co-op Members may refer to their agreement with us for additional information about our security practices.

Your Rights and Choices


Communications from Us

You may instruct us not to use your information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using our contact information below.  In many commercial email messages, you can also opt out by following instructions located at the bottom of such emails.  Removing your name from the email list may take a reasonable amount of time.  Even if you opt out from receiving marketing messages from us, you will continue to receive administrative messages from us, such as order confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you.

Jurisdiction Based Rights

Access, Correction & Deletion Rights

Laws in certain jurisdictions grant consumers the right to exercise certain controls and choices regarding your information.

For example, if you are a resident of California, Colorado, Connecticut, Utah, or Virginia, to the extent applicable, you (or, in certain of these states, an authorized agent acting on your behalf) may request that we:

  • provide access to and/or a copy of certain information we have about you;
  • correct information which is out of date or incorrect;
  • delete certain information which we have about you;
  • transfer your information to a third-party provider of services; and
  • revoke your consent for the processing of your information.

California residents may also request information about the categories of personal information we collect, disclose or sell or share about you; the categories of sources of such information; the business or commercial purpose for collecting or selling or sharing your personal information; and the categories of third parties to whom we disclose personal information. Such information is also set forth in this Privacy Policy.

Residents of certain other jurisdictions may be able to request one or more of the above under applicable law.

Applicable law may further provide you with the right to not be discriminated against for exercising your rights.

If you would like further information regarding your legal rights or would like to exercise any of them, you may contact us by email at [email protected] or submit a request here.

Please note that certain information may be exempt from such requests under applicable law.  For example, we need to retain certain information in order to provide our Services to you.  We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address.

Depending on your jurisdiction, you may designate an agent to exercise certain rights.  We will take steps to verify the identity of the agent, and that your agent has been authorized to make a request on your behalf.  Such steps may include requiring that the agent submit a signed written authorization or a copy of a power of attorney.

If we deny your request in whole or in part, you may have the right to appeal the decision; depending on your jurisdiction (such as Colorado, Connecticut, and Virginia) you can email us at [email protected] to appeal.

Opt Out of Sale, Share or Processing for Targeted Advertising

Residents of California, Colorado, Connecticut, Utah, and Virginia may also opt out of the “sale” of certain information and, to the extent applicable, opt out of the sharing or processing of their information for targeted advertising. You can exercise that right by following the steps at “Your Privacy Choices” in the footer of this Website.

  • We “sell” Co-op Information obtained from Co-op Members and  third parties who are not Co-op Members, such as name, email address, phone number, mailing address, and inferences about your potential campaign or organization interests, to Co-op Members.
  • We also provide third parties, such as advertisers and advertising networks (e.g., social media networks), Website Information including certain identifiers and internet or other similar network activity (e.g., browsing history and usage information) in order to enable marketing to you and delivery of targeted advertising about the Services on other sites.  The disclosure of such personal information listed above to these third parties to assist us in providing these services may be considered a “sale” of personal information under applicable law and is sharing of personal information and the processing of personal information for targeted advertising purposes.

Certain Nevada residents may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to the extent our customers qualify as “operators.”  If you are a Nevada resident, you may submit a request to opt out of sales under Nevada law by emailing us as [email protected].

California Privacy

The California Consumer Privacy Act of 2018, as amended (“CCPA”) provides certain rights to residents of California.  If you are not a California resident, this does not apply to you and you should not rely on it.  In this section, the terms “personal information” and “sensitive personal information” have the meanings set forth in the CCPA.

Categories of Personal Information We Collect and Our Business Purposes for Collecting and Using this Information

The chart below provides information about our practices in the twelve (12) months leading up to the effective date of this policy in relation to the categories of information collected about California residents generally and the purposes for which we collect and use the information.  We do not collect information deemed “sensitive” under the CCPA, such as race, ethnicity, sexual orientation, or information about specific medical conditions.

Category of Personal Information Business Purpose
A. Identifiers, such as name, alias, postal address, online identifiers, telephone number, and email address. For Co-op Information:

  • Provide Services purchased by Co-op Members
  • Internal purposes (e.g., improving our Services)

For Customer Information and Website Information:

  • Provide the Services
  • Customer support
  • Provide recommendations, personalize your experience, and customize the Services
  • Understand your interests and engage in research, analysis, and reports, including for product improvement
  • Our marketing and advertising purposes
  • Security, safety, fraud, and legal compliance, including dispute resolution
  • Other purposes for which we seek your consent
B. Commercial information, such as supporter donation records or other purchasing or consuming histories or tendencies. For Co-op Information:

  • Provide Services purchased by Co-op Members
  • Internal purposes (e.g., improving our Services)
C. Internet or other similar network activity, such as browsing history and usage information for Website visitors. For Website Information:

  • Provide the Services
  • Customer support
  • Provide recommendations, personalize your experience, and customize the Services
  • Understand your interests and engage in research, analysis, and reports, including for product improvement
  • Our marketing and advertising purposes
  • Security, safety, fraud, and legal compliance, including dispute resolution
  • Other purposes for which we seek your consent
D. General geolocation data. For Website Information:

  • Provide the Services
  • Customer support
  • Provide recommendations, personalize your experience, and customize the Services
  • Understand your interests and engage in research, analysis, and reports, including for product improvement
  • Our marketing and advertising purposes
  • Security, safety, fraud, and legal compliance, including dispute resolution
  • Other purposes for which we seek your consent
E. Professional or employment-related information, such as current or past job history. For Customer Information:

  • Provide the Services
  • Customer support
  • Provide recommendations, personalize your experience, and customize the Services
  • Understand your interests and engage in research, analysis, and reports, including for product improvement
  • Our marketing and advertising purposes
  • Security, safety, fraud, and legal compliance, including dispute resolution
  • Other purposes for which we seek your consent
F. Financial Information, such as payment information provided by Customers using our Services. For Customer Information:

  • Provide the Services purchased by Customers
  • Security, safety, fraud, and legal compliance, including dispute resolution
G. Inferences drawn from other personal information. For Co-op Information:

  • Provide Services purchased by Co-op Members
  • Internal purposes (e.g., improving our Services)

As described in the “Information We Collect About You and How We Collect It” section above, we obtain the categories of personal information listed above from our customers (e.g., Co-op Members), directly from you when you purchase Services or send us information, and when you visit our Website.

Our Disclosure, Sharing, and Sale of Personal Information

We will share and sell the information collected from and about you as discussed above for various business purposes and with third parties including Co-op Members, and, in certain circumstances, advertising platforms.  These business purposes often involve cross-context behavioral advertising, also known as “targeted” advertising.

The chart below describes how and with whom we disclose personal information, and whether (based on the CCPA’s definition of “sell”) we believe we have “sold” or “shared” a particular category of information in the prior 12 months.  “Sharing” information means making available the information we collect or letting others collect such information for cross-context or “targeted” advertising.   Because we often earn money in exchange for valuable consideration and/or making available information for advertising purposes – we are involved in both a “sale” and a “share” of that information.

 

Category of Personal Information Business Purpose Whether We “Sold” or “Shared” This Category of Information in the Last 12 Months
Identifiers, such as name, alias, postal address, online identifiers, telephone number, and email address. Co-op Information

  • Co-op members

Website Information

  • Advertising networks and media platforms, data analytics providers
  • Social networks
Yes
Internet or other similar network activity, such as browsing history and usage information for Website visitors. Website Information

  • Advertising networks and media platforms, data analytics providers
  • Social networks
Yes
Inferences drawn from other personal information. Co-op Information

Co-op members

Yes

In addition to the categories of third parties set forth in the above chart, we may also disclose any of the categories of personal information we collect as set forth in the “How We Disclose Information” section, including with or for:

  • Governmental entities for legal purposes;
  • Affiliates and subsidiaries in event of a corporate transaction;
  • Our vendors to perform business purposes on our behalf, such as analytics, hosting, fraud prevention, and other services;
  • Aggregate and/or de-identified information that can no longer be linked to your device

Your CCPA Right to Opt Out of “Sale” or “Sharing” of Personal Information

California residents have a right to direct us not to “sell” or “share” certain personal information as those terms are defined in the CCPA. You can exercise that right by following the steps at Your Privacy Choices in the footer of this Website.

Your browser may also offer a way to activate a legally required browser based opt out signal, such as the Global Privacy Control signal (“GPC”). Our websites each treat qualifying browsers for which the user has activated such signal as having opted out of what CCPA calls a “sale” of any California personal information that is collected on that site from that browser using cookies and similar technology. You can override that treatment for a GPC-enabled browser by using the “Your Privacy Choices” link available on the Website’s footer.

Opting out of “sales” and “sharing” limits only some types of disclosures of personal information, and there are exceptions to the rights described in this section.

Please note that we do not “sell” or “share” personal information (as those terms are defined under the CCPA) if we have actual knowledge that the consumer is less than 16 years of age.

Retention

We retain your information only for as long as we determine it is necessary to provide the Services and to fulfill the transactions you have requested, or for other necessary purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.  In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the utility of certain data to our Customers and our contracts with them, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests.  The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information.  For example, if you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law.  We may retain cached or archived copies of your information.

Non-Discrimination

We will not discriminate against you as set forth in the CCPA for exercising any of your CCPA rights, unless permitted by the CCPA.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

Children’s Privacy

Our Services are not intended for children under 18 years of age.  We do not knowingly collect personal information from children under 18.  If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will promptly take steps to delete that information.  If you believe we might have any information from or about a child under 18, please contact us at [email protected].

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page.  If we make material changes to how we treat our users’ personal information, we will notify you in accordance with applicable law, such as by email or through a notice on the Website home page.  The date the privacy policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information


To ask questions or comment about this privacy policy and our privacy practices, contact us at [email protected].