(effective May 22, 2023)
The Democratic Party Committee Abroad, doing business as Democrats Abroad (also known as “DA”), is committed to protecting the privacy and security of your personal information. Democrats Abroad collects different types of information from you when you use our web-based services ("Services") [See Part I]; and Democrats Abroad separately maintains different types of information from you if your personal data is provided to Democrats Abroad under a data sharing agreement with a third party (“Third Party Data”) [See Part II].
At Democrats Abroad, we are committed to protecting your privacy online. Democrats Abroad will hold any information you provide us here with the utmost care, with appropriate security measures in place that protect the privacy and confidentiality of your personal information. Democrats Abroad will use the information you provide for the following purposes: to validate your membership; to provide you with access to “members only” sections of the Democrats Abroad website; to allow Democrats Abroad officers as appropriate to contact you with voting reminders and with information about upcoming activities in your Democrats Abroad chapter and/or interest group(s); and to allow you, should you so wish and only with your consent, to participate actively in the “members only” sections of the website. Should you choose to contribute to the Democrats Abroad posts, your login name will appear along with your text. You can change this default setting and change your login name to something else if you would like. To register as a member of Democrats Abroad, we will not ask you for any sensitive information (such as social security number, driver’s license or passport number), and we do not otherwise maintain any information about you that you have not freely provided to us.
Democrats Abroad complies with the European Data Privacy Regulations ("GDPR"). This means that we will never sell or share your personal information, regardless of where in the world you live, with any third party. This includes but is not limited to the Democratic National Committee (“DNC”) or other political organizations in the United States or elsewhere.
If you join Democrats Abroad, you will have given us permission to transfer your name, contact information, and any voting state information you may have provided to the Democrats Abroad membership database, and have agreed to this privacy statement. You may revise or update your information at any time by going to your “my profile” link on the website.
Democrats Abroad will not use any information provided to us here for any purpose other than in connection with your membership in Democrats Abroad and the activities of Democrats Abroad. If you have chosen to provide your voting residence information, Democrats Abroad will send you additional information about voting in your last state of residence as it becomes available. Democrats Abroad will not disclose your information to third parties for any other purpose unless we first obtain your consent, except as required by applicable law or regulation. Democrats Abroad may use aggregate information about its members for statistical reports, but it will not be possible to identify you from such reports.
Any information that you provide to the Democrats Abroad membership database will be collected and transferred to the database stored on a secure server maintained by the Democratic Party Committee Abroad. Democrats Abroad is committed to providing your information with a very high level of privacy protection. You should be aware, however, that applicable laws and regulations protecting personal information in the United States may not be the same as that provided in other jurisdictions, including those that belong to the European Economic Area.
You may also contact us directly by U.S. mail at Privacy Internet Operations Division, Democrats Abroad, PO Box 15130, Washington, DC 20003, USA.
LEGAL BASIS FOR COLLECTING YOUR PERSONAL INFORMATION
When we collect and process personal information from you, your consent and agreement to abide by our contractual terms establish the primary legal basis for doing so:
Other legal bases for collecting and processing your personal information include:
- Compliance with legal obligations to which Democrats Abroad is subject;
- Legitimate interests of Democrats Abroad, provided that such legitimate interests do not interfere with other fundamental rights and freedoms you possess.
- Consent by the data subjects to the collection of the personal information.
INFORMATION WE COLLECT AND RECEIVE
We collect personal information about you and the devices you use to access and interact with us and our Services. We collect:
(a) Registration information:
you give us when you sign up as a member of DA
(b) Financial information:
you give us when you contribute to DA
(c) Technical and device information:
information from your mobile or computer device when you use our Services
your questions, suggestions or views
(e) Third party information:
information about your use of our Services that is shared with third party platforms and services connected with our Services
(a) Registration information
When you register or sign up to use our Services we collect information about you including your name, user name, status as a citizen of the United States of America, contact details, date of birth, age information, residential address abroad, voting address in the United States, a general statement of your political opinions and party affiliation, personal preferences and additional information that you choose to provide. We may also collect your contact information so that you can sign-up to receive communications from Democrats Abroad. As part of any required sign in to use our Services, we will verify the information that you use to login.
We do not control the information that is sent from your browser to third parties, including social media platforms, analytics companies and advertising networks which receive information in the normal course of your online activities.
(b) Financial information
If you choose at any time to make a donation (i.e., financial contribution) to Democrats Abroad, you may be identified as a donor on our membership database, but your financial information will not be entered or held on this database. Your financial information will be securely archived by a trusted third party in compliance with U.S. federal laws and regulations. Democrats Abroad has authorized these third-party payment services providers to process your financial information, and only authorized officers of Democrats Abroad will have the ability to access this information.
In other situations, and only based on direct communication with you and with your consent, we may collect payment information such as credit or debit card details (including expiration dates) and other financial information such as your bank account information, your name and address in order to verify your financial contributions to Democrats Abroad, process any refund payments, contact you to resolve any issues, and/or deliver Services to you. We may collect this information from you and/or third party services that have been authorized to receive financial contributions for Democrats Abroad, such as Act Blue.
(c) Technical and device information
We collect information from your web browsing activity about the way you use our Services. We may also collect information about you from the notifications or messages you post or send online as well as what you search for, look at and engage with. Information obtained from social features used in connection with our online Services, such as forums and chat functionality, may be stored, copied or used by Democrats Abroad, the public, or third-party companies.
See also our Cookies Policy
We will collect personal information from the messages and reviews you post on our social forums, and when you contact us, for example with a question, problem or comment. If you contact our customer services team by email or post, we will keep copies of your correspondence with us for as long as necessary to deal with your query. For more information, see section 2 (e), below, on how we use third party information.
(e) Third party information
We may share information obtained from your use of our Services with third parties to provide you with an optimal experience, to facilitate use of the Services and to enable you to use our Services on various platforms.
HOW WE USE THE INFORMATION WE COLLECT
We may use the information we collect from you in the following ways:
(a) Registration information
(i) to create your membership account and so you can access our members only Services;
(ii) to identify you when you sign-in;
(iii) to give you access to your user preferences;
(iv) to contact you for your views on our Services;
(v) to notify you of changes or updates to our Services; and
(vi) for marketing purposes, based on your communication preferences.
Your registration information enables us to provide you with access to our Services under the agreements we have with you. It helps us to authenticate your access, to contact you for your views or to provide information important to our members, and to notify you of important changes or updates to our Services. It also enables us to contact you to verify that you still reside overseas, which is a condition precedent to eligibility for continued membership in Democrats Abroad. This process is called membership verification. We may contact you at any time to verify your membership, but we focus our annual membership verification efforts from approximately mid-November to January 31st. You can verify your membership on your own by logging in to your account, clicking on the “account settings” tab, and clicking “save private settings”. Your membership will be verified whether or not you enter any new information.
Where we have your consent and in accordance with your stated communication preferences, we may also contact you for marketing purposes to let you know by post, email, telephone, mobile or in-app messaging about our other services or provide you with information important to our members, such as events, political news, fundraising solicitations, overseas voting information and reminders, and so on.
If you no longer want us to use your data in this way or generally change your mind about receiving marketing communications, you can unsubscribe at any time, either by using the unsubscribe option in the communication you receive or by changing your communication settings. Please note that we will retain a record of the user information when you unsubscribe from our marketing information for the legitimate purpose of ensuring that we do not contact you further in this way, during the period of your objection.
(b) Financial information
(i) to verify your financial contribution to Democrats Abroad and process any refunds;
(ii) to reply to any queries and questions and to resolve problems;
(iii) to carry out analysis and research to develop our Services; and
(iv) to protect you, our other members and our Services by seeking to detect and prevent fraud or other acts in breach of our user agreements or policies relevant to the Services.
This information will enable us to verify your financial contributions with third party services and to contact you in order to assist with resolving any problems with your contribution and to process any refund payments that you may be due.
We will also use and analyze information on transactions on your account for our legitimate interests by data matching or statistical analysis so that we can administer, support, improve and develop our Services and to help us detect and prevent fraud, or other illegal activities, or acts prohibited by our terms of service or any policies applicable to the Services.
(c) Technical and device information
(i) to provide you with an optimal experience;
(ii) to understand how you interact with our Services;
(iii) to provide Services you request;
(iv) to measure and analyze the use and effectiveness of our Services;
(v) to understand which of your devices are using our Services;
(vi) to provide a safe and fair online environment in connection with our Services;
(vii) to measure and analyze the use and effectiveness of our Services;
(viii) to customize and optimize the targeting of our advertising in connection with our Services and across other websites and Services;
(ix) to operate and improve our Services; and
(x) to fix errors.
We analyze information about how you engage with our Services to understand how our Services are used and to provide you with an optimal user experience. We use anonymous data in order to analyze and produce statistics relating to the habits, usage patterns and demographics of users as a group or as individuals. This allows us to deliver you personalized content, helps us understand the features of our Services that appeal to you and allows us to manage our communications strategy, among other things.
When you interact with or visit our websites, we may automatically collect information about you such as the type of internet browser or mobile device you use, any website from which you have come to any of the Democrats Abroad Websites, and your IP address (the unique address which identifies your device on the Internet) and your operating system, which are automatically recognized by our web server.
We use internet log files to monitor traffic related to our Services, resolve technical problems and to detect and prevent fraud. We use these technologies to provide us with information, such as when an email is opened, or to develop statistics on the effectiveness of communication with our members on or through our websites. In some cases, we use this information to send you communications based on your interests.
We also use technical and device information to operate and improve our Services, measure our effectiveness, set up and maintain accounts, identify and fix errors and to help keep online content fair and safe and to resolve related disputes.
(i) to reply to your questions or queries;
(ii) to record comments and information which you provide via our Websites or other forums we provide; and
(iii) to conduct analysis and research to improve and develop our Services.
We use your feedback to reply to your questions or queries, to provide customer support and resolve problems relating to any of our Services under the agreements that we have with you. We may also publish reviews that you submit to us for this purpose about the Services and may conduct analysis of feedback for the purpose of improving and developing our Services.
(e) Third party information
(i) to facilitate sharing on social networks; and
(ii) to enhance your experience when using our Services.
See also our Cookies Policy.
WHEN WE SHARE INFORMATION
We may share the information we collect about you (subject to the necessary security, contractual and transfer safeguards). In delivering Services to you, we may share your personal information with:
- Authorized officers or volunteers of Democrats Abroad. The Democrats Abroad membership database is maintained, and personal information is processed, by authorized officers and volunteers at various levels of the organization, including the global, country, chapter, and other levels; only authorized members of Democrats Abroad are granted access to personal information of other members, subject to limitations and restrictions intended to protect your privacy. At the global level, your information may be accessed by authorized officers or volunteers of Democrats Abroad anywhere in the world, but they may not share your information with members of Democrats Abroad who are unauthorized to process your information and may not share your information for any non-Democrats-Abroad-related purposes. Certain elected officials at the country level and authorized country-level volunteers are only granted access to process the personal information of members of Democrats Abroad who reside within their country’s jurisdiction, and in some cases, processing is limited to the chapters or precinct level. For example, if you reside in Germany, your registration information will be accessible to authorized members of Democrats Abroad who reside in Germany, but your information cannot be accessed by members of Democrats Abroad who reside in other countries. Some authorized officials or volunteers at the sub-country level (e.g., the Berlin Chapter), will be able to access your information if you live within the chapter’s designated territory, but they cannot access your information if you live outside the chapter territory, even if you still reside in Germany.
- Third parties in order to undertake various activities or services on our behalf in supporting the Services. This includes payment processing providers facilitating credit and payment card transactions, website and application support and hosting providers for online services and providers for the delivery of promotional, digital advertising or other communications, such as MailChimp.
- We may use the information that you provide if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or to enforce the relevant terms of service and any other agreement; or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organizations such as credit agencies, law enforcement or government bodies or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection, or in legal proceedings.
INFORMATION COLLECTION FOR CONTRIBUTIONS
We do not control information which is sent from your browser to third parties, including social media platforms, analytics companies and advertising networks that receive information in the normal course of your online activities.
Personal information may be transferred to other countries where Democrats Abroad or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access the Services or, in the case of transfers subject to European law, may not be subject to an adequacy decision by the European Commission (EC). An adequacy decision is a decision taken by the EC establishing that a third country provides a comparable level of protection of personal data to that in the EU, through its domestic law or its international commitments.
Where Democrats Abroad transfers personal information it will seek to take account of any applicable legal obligations relevant to personal information transfers. In the case of transfers of personal information out of the European Economic Area, it will, in the absence of an EC adequacy decision relevant to the destination country, seek to rely on appropriate safeguards such as enter into appropriate EC approved standard contractual clauses relevant to personal data transfers between data controllers or between a data controller and a data processor. For reference, see the European Commission's website.
SECURITY AND DATA RETENTION
Your privacy is important to us and we place great importance on the steps we take, including technical and organizational measures to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.
Where you have chosen a password which allows you to access any of our Services, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. We will not be liable for any unauthorized transactions entered into using your username, personal information and/or password.
Your personal information will be retained by us for the duration of your use or access to our Services and may be retained for a period after this time as necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws and obligations. This may include retention necessary to meet our tax or Federal Election Commission (United States) reporting requirements as well as time required to enforce any obligations in our agreements, or to identify, issue or resolve legal proceedings.
We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving communications from Democrats Abroad for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.
We will take appropriate steps to seek to destroy or permanently de-identify personal information at the point this information is no longer needed by us for our business or legal purposes.
For more information about exercising your rights with respect to our data processing activities, or if you no longer wish to use our Service, see details below about your choices and rights.
THIRD PARTY DATA
HOW WE COLLECT THIRD PARTY DATA AND WHY
We enter into data sharing agreements with Democratic State Parties to obtain data of likely democratic and independent voters from a particular state who reside overseas. This data is public information in the United States and is processed by the State Democratic Party in the United States, and it includes the information the data subject provides to their secretary of state in order to vote absentee, including their full name, voting address in the state in the United States, overseas address, email address, telephone number(s). This data does not include Social Security or passport numbers. We maintain the data obtained in a segregated database in order to ensure that all such data subjects may exercise their rights (as described in Section 7 below). We obtain this data in order to reach out to the data subjects through a variety of means, including, phone banking, text banking, mailing, and emailing, in order to remind them to request their ballot for upcoming elections and offer voting assistance. Data subjects may exercise their rights under GDPR (as described in Section 7 below) and their data will be treated accordingly.
YOUR CHOICES AND RIGHTS
Services: You have options and choices over how we use your personal information. You may be required to register or sign in to use or access some of our Services and may need to provide personal information to create a user profile which is associated with your use of our Services. If you wish to amend the personal information that you use to access our Services, you can do so by logging into your account at www.democratsabroad.org or by contacting us using the details in section 8 below.
If you sign up to receive communications from us, you will be asked to confirm your communication preferences and given the opportunity to unsubscribe at any time.
You can contact us directly with requests to correct, erase, restrict, object to, or move your personal information. If you do not want us to process and/or access your personal information, you may be unable to use some of our Services.
You have options and choices over how we use your information. We provide you with tools to access and update specific information relating to your use of the Services at any time. If you sign in to access certain Services, you can update and amend your key contact information directly.
DATA SUBJECT RIGHTS
In this Section, we have summarized the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
Right to Object
You can exercise this right if:
- Processing relies on legitimate interest
- Processing is for scientific or historical research
- Processing includes automated decision making and profiling
- Processing is for direct marketing purposes
Right of Access
- You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
- We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
Right to Be Informed
- We are required to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
Right to Rectification
- If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
Right to Erasure
- If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
Right to Restrict Processing
- You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
- Processing is unlawful
- We no longer need the personal data, but it is required for a legal process
- You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
Right to Data Portability
You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
- Processing is based on consent
- Processing is by automated means (i.e. not paper based)
- Processing is necessary for the fulfillment of a contractual obligation
- You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
In principle, members of Democrats Abroad must be of voting age in the United States, which means that they are over the age of 18. However, any United States citizen may join Democrats Abroad if he or she will be 18 or older on the date of the next federal election. Because federal elections occur every two years, it is possible for a 16-year-old to join Democrats Abroad.
Protecting the privacy of young children is especially important to Democrats Abroad. For that reason, Democrats Abroad does not knowingly collect or maintain personal information or non-personally identifiable information from users under 16 years of age, other than as permitted by law in support of our internal operations.
If Democrats Abroad learns that personal information of users under the age of 16 has been collected, other than for support of the internal operations, Democrats Abroad will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal information about your child who is under 16 years of age, you may contact us using the details provided below.
YOUR QUESTIONS AND HOW TO CONTACT US
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us
- via email on [email protected]
- by writing to us at:
- Data Protection Officer, Democrats Abroad
- PO Box 15130
- Washington DC 20003
- United States of America
You can also contact our Data Protection Officer at [email protected].
Alternatively, you can make a complaint to your relevant supervisory authority, you can find list of EEA supervisory authorities at this link.