Effective as of: March 4, 2013
The American Civil Liberties Union of Kentucky and the American Civil Liberties Union of Kentucky Foundation (collectively, “ACLU of Kentucky”) have a long history of being at the forefront of protecting individual privacy, and we are particularly committed to protecting the personal information that you provide and entrust to us when using the ACLU of Kentucky’s websites. This online privacy statement (the “Privacy Statement”) describes how we treat all user data collected by the ACLU of Kentucky during your visit to the ACLU of Kentucky Site, both technical data that is automatically collected and voluntarily submitted data. The ACLU of Kentucky comprises the American Civil Liberties Union of Kentucky and the American Civil Liberties Union of Kentucky Foundation. To learn more about the differences between the two organizations, click this link.
For purposes of this Privacy Statement, the “ACLU of Kentucky Site” is the website whose home page is www.aclu-ky.org, and includes all web pages whose domain name contains the following: www.aclu-ky .org and some pages of secure.aclu.org where a link to this privacy statement exists. Additionally, this is not the privacy statement for internet sites (e.g. blogs, forums or social networking sites) where ACLU of Kentucky has a presence that are on websites other than the ACLU of Kentucky Site. Further, this is not the privacy statement for the websites of the national operations of the ACLU, the American Civil Liberties Union or the American Civil Liberties Union Foundation (“ACLU National”) or for any ACLU local affiliates other than ACLU of Kentucky, and you should refer to the privacy statements on those organizations’ websites or contact those organizations to learn the manner in which they treat information you provide to them through their websites’ (or provide to them in any manner other than through the ACLU of Kentucky Site). This also is not the Privacy Statement applicable to websites linked to from the ACLU of Kentucky Site. See also “Third-Party Functionality” to learn about third-party optional functionality that appears on the ACLU of Kentucky Site.
The ACLU of Kentucky may occasionally update this Statement. We will post any changes on this web page, so be sure to check back periodically. If we do make material changes, we will post a notice on our home page that the Privacy Statement has been modified and provide a link to the revised Privacy Statement. Any information that you submit after a change has been posted will be subject to the new provisions.
User Data We Collect
We collect two types of user data: (1) technical data that is automatically collected from all visitors to the ACLU of Kentucky Site (“Automatically Collected Data”); and (2) data that you voluntarily submit to us (described below under “Voluntarily Submitted Data”).
Automatically Collected Data.
We automatically collect and store Internet Protocol (“IP”) addresses and domain names of the originating visitor’s computer on our server and may know some information you have previously provided through cookies. (See the section on “Cookies” below for more information.) We also track the number and frequency of hits per page as well as length of website visit, using IP addresses and/or session cookies. In addition, if you come to the ACLU of Kentucky Site from a website link, we may also identify the source of that link.
Voluntarily Submitted Data.
We may collect and store Voluntarily Submitted Data, including personal data, that you voluntarily provide, such as your name and postal address, phone number, e-mail address, and similar information, and transactional information, such as giving and action-taking history, when you participate in certain activities on the ACLU of Kentucky Site, including (but not limited to) when you:
· join or renew your membership to the ACLU of Kentucky;
· make an additional contribution to support the ACLU of Kentucky;
· sign up for our ACLU of Kentucky e-mail network;
· send correspondence , place a call, or inform us about a call to your government representative, or send correspondence to a friend (e.g., when you tell-a-friend or send an e-card) or to other targeted representatives through the ACLU of Kentucky Site;
· register for our message board;
· register online for an event;
· participate in one of our online petitions or surveys;
· post a blog comment;
· submit feedback to the ACLU; or
· participate in any activity that requires your Voluntarily Submitted Data.
When you send correspondence to a friend, your friend’s email address is only captured by us temporarily in order to complete your send request.
Other Collected Data.
We also may collect data concerning your use of the ACLU of Kentucky Site or interest in ACLU of Kentucky communications such as by using an embedded image in an email in order to track whether you open our email communications and using a URL contained in an email we send to you that enables us to identify that you have taken an action using a webpage. We may use this data for a number of reasons, including taking account of your interests in our work so that you do not have to miss the opportunity for us to inform you about, and offer you the chance to take action concerning, the ACLU of Kentucky issues you care about most, and in order to simplify the process of your signing petitions and filling out surveys.
We may transfer a Long-term Cookie in circumstances in which you are notified prior to the cookie being stored. For example, when you select a “remember” option on the ACLU Kentucky Site, a Long-term Cookie will be stored on your browser on your computer or device solely for the purpose of automatically filling in the information you have asked to be remembered, for example, automatically filling in your password when you log in to the ACLU of Kentucky Site or your postal address when you write a letter to your representative.
We may use Session Cookies whenever you visit the ACLU of Kentucky Site for our website traffic analytics application and the Site’s interactive applications, such as in our online advocacy. Session Cookies last only as long as your browser session. They expire when you close your browser and are not permanently stored on your computer or device. We also use Session Cookies in e-mails containing the HTML-format. If you select “text-only” format preference, emails sent to you will not contain any Session Cookies.
Some of our website analysis and functionality, such as maps and videos, are provided through third-party functionality and require the use of Short-term Cookies. These Short-term Cookies are set to expire within one hour of their being placed on your browser on your computer or device.
How We Use The Data We Collect
In addition to the uses described above, we use Automatically Collected Data to identify the source outside of the ACLU of Kentucky Site of user traffic (for example, umich.edu, or aol.com) so that we can evaluate what content is persuading web users to become involved in the ACLU of Kentucky’s work. We use Automatically Collected Data, including IP addresses and/ or Session or Short-term cookies, that indicates which sections of the ACLU of Kentucky Site are most visited so that we can perform website traffic analysis, evaluate the popularity of our different web pages and continue to improve the ACLU of Kentucky Site. In order to learn which ACLU of Kentucky website content inspired you to undertake action such as supporting our work protecting free speech, voting rights or reproductive freedom, we also use Automatically Collected Data we gather just prior to and in connection with your submission of Voluntarily Submitted Data by joining or contributing to ACLU of Kentucky or taking action on any ACLU of Kentucky webpage. Automatically Collected Data also may be associated with the Voluntarily Submitted Data you provide to us except to detect security intrusions or certain unlawful activity.
We use your Voluntarily Submitted Data for various purposes:
· To fulfill the request for which you specifically provided the data, including sharing the data with its intended recipient (e.g., delivering a petition you sign or a letter you wish to send to the recipient of the petition or letter);
· To analyze actions taken through our website so that we can learn which civil liberties issues prompt you to become involved in the fight to protect our freedom;
· To periodically communicate with you concerning ACLU of Kentucky matters, such as delivering to you information and updates on our activities and action alerts, unless you opt out of receiving such information and updates;
· To indicate you as the author of any comment you post, including on any ACLU of Kentucky Site blog or forum, when you opt to identify yourself as the author or when posting such comment requires such identification, and to display any personally identifying or other information you voluntarily include in such comments;
· To personalize the content that you see based on the activities that you have selected on the ACLU of Kentucky Site;
· To allow you to set and change user preferences;
· To allow you to renew your membership in the ACLU of Kentucky;
· To offer you other ways to support the ACLU of Kentucky, including solicitations for additional contributions if you have not opted out of receiving such communications;
· To confirm your contribution to the ACLU of Kentucky;
· To confirm your registration to an ACLU of Kentucky event;
· To respond to an inquiry or feedback you have made to the ACLU; and
· To follow up with you with an email specific to an activity you have participated in or intend to participate in.
If your Voluntarily Submitted Data includes a U.S. zip code or state and you are a member, donor or subscriber to ACLU of Kentucky information, unless you choose otherwise (see Your Ability to Choose below), we may also share your Voluntarily Submitted Data with ACLU National, which may use that information for any purpose for which we may use that information as described in this Privacy Statement and, if you are a member, donor or subscriber to ACLU of Kentucky and you list as your address a U.S. address that is within the geographic region of another local ACLU affiliate, we may share your information with that local affiliate which may use that information to:
· If you have not opted out, to periodically communicate with you concerning local affiliate matters, such as delivering information and updates on the local affiliate’s activities, action alerts concerning local matters and invitations to local events;
· To confirm your registration to an event;
· To follow up with you with an email specific to an activity you have participated in or intend to participate in; and
· If you have not opted out, to offer you other ways to support the ACLU of Kentucky, including solicitations for additional contributions.
In some instances when you voluntarily take an action that uses email functionality, you will be alerted immediately following taking that action that you have opted in to receiving further email communications unless you opt out of receiving such communications by unsubscribing. If you voluntarily join a petition that is to be delivered to a third party, such as a governmental figure or agency, we will deliver to that third party the Voluntarily Submitted Data you submit in connection with joining the petition. Additionally, in order to encourage others to participate and show the geographic reach of our supporters, we also may publicize your participation in the petition on the ACLU Site by showing your first name and last initial and the city and state you submit in connection with joining the petition, but not other information you submit in connection with joining, such as your full last name and street or email address.
The ACLU of Kentucky Site is hosted by servers in the United States. Accordingly, if you are located outside of the United States, the Voluntarily Submitted Data you provide to us will be transferred to the United States. By submitting your Voluntarily Submitted Data, you consent to its transfer and storage in the United States and its use in accordance with the purposes for which it was originally collected (see below regarding third-party sharing of Voluntarily Submitted Data from non-U.S. residents).
If you are a U.S. resident, we may also from time to time combine your Voluntarily Submitted Data with some publicly available data collected from third parties to improve our services to you and for our own internal marketing, communications, and fundraising purposes.
Third Party Sharing
Generally, we do not share Automatically Submitted Data, Voluntarily Submitted Data or Other Collected Data with third parties. However, we do share such data with those third-party service providers who fulfill your orders or transactions, contact you on our behalf, or facilitate some other aspect of ACLU of Kentucky activities, services or products, including those third-party service providers who collect, process, store and transmit information we collect on this website on our behalf and those third-party service providers we use to assist us in our fundraising and communications efforts. These service providers have access to your Voluntarily Submitted Data solely for the purpose of providing these services to us on our behalf, and they are contractually prohibited from sharing your Automatically Submitted Data and Voluntarily Submitted Data with third parties other than subcontractors assisting them in their providing these services to us who also are contractually prohibited from sharing your Automatically Submitted Data and Voluntarily Submitted Data with any other third parties. Please note that we do not share data from non-U.S. residents with any other third parties (except where required by law, see below), even if a non-U.S. resident has subsequently authorized such use, for example, by checking an opt-in request.
We may also share the Voluntarily Submitted Data of members and donors who are U.S. residents with other non-profit organizations and publications (“Sharing Organizations”), but never to any partisan political groups or to groups whose programs are incompatible with ACLU of Kentucky policies. We never give your Voluntarily Submitted Data directly to the Sharing Organizations; instead we send the list to a third-party service provider that prepares the communication for the Sharing Organization (and that is contractually bound to use your Voluntarily Submitted Data only for this purpose and not to share it with any third parties other than subcontractors assisting them in their providing these services to us who also are contractually prohibited from sharing our Voluntarily Submitted Data with any other third parties). The Sharing Organizations never see our list and never know what names and related contact information are on it other than the names and contact information of those individuals who respond to the Sharing Organizations’ communication. Exchanging lists can enable the ACLU of Kentucky to expand our membership base. However, you can choose to opt out of having your data shared. To learn more, read the section on “Your Ability to Choose” below.
Finally, we may disclose and use Voluntarily Submitted Data regardless of where you reside in special circumstances when it is necessary to enforce our User Agreement or this Privacy Statement, or when we, under what we hope to be extraordinary and infrequent circumstances, in good faith, truly believe that the law requires us to disclose your Voluntarily Submitted Data to third parties.
Except as described in this Privacy Statement, we will not share your Voluntarily Submitted Data with any third party unless we first notify you and offer you an appropriate choice to consent to such further use, for example, through an opt-out or opt-in request.
As discussed in the preceding section, to support certain functions carried out on the ACLU of Kentucky Site, the ACLU of Kentucky uses third-party service providers. In limited instances with respect to specific optional functions on the ACLU of Kentucky Site, these third parties may have data collection, use or security procedures that differ from the practices outlined in this Privacy Statement and that may impact users of those optional functions. For example, a third-party service provider may. allow us to stream videos through the ACLU of Kentucky Site on an embedded video player (e.g., the YouTube embedded player) and, by viewing that video on the ACLU of Kentucky Site, you are actually accessing that service provider’s website and subject to its data collection, use or security procedures. This third party may, for example, transfer a Long-term Cookie to your computer when you use this functionality. Please make sure that you review that third party’s procedures prior to using that optional functionality. In cases where it is not clear that you are using a third party’s functionality (i.e., it is not branded as the functionality of a third-party), we will notify you that your use of the functionality is subject to a third party’s data collection, use and security procedures and identify that third party.
It is important to note that standard email sent across the internet is unencrypted. While emails ACLU of Kentucky personnel send to one another within the ACLU of Kentucky system is encrypted, emails that leave the ACLU of Kentucky system or are sent to the ACLU of Kentucky from outside the ACLU of Kentucky system—including the information in those emails and the email addresses—are not necessarily secure. ACLU of Kentucky does not, and requires that its third-party service providers that have access to Voluntarily Submitted Data do not, transmit emails outside the ACLU of Kentucky system that contain Voluntarily Submitted Data unless that information is sent in a secure (e.g., password protected) manner or the ACLU of Kentucky has your consent.
With your consent, such as when you send emails to or receive emails from ACLU of Kentucky personnel or you decide to use any ACLU of Kentucky website email functionality, including Email a Friend, contacting legislators or engaging in other advocacy communications via email, the information transmitted in those communications, including your email address, will be transmitted across the internet in an unencrypted manner.
In furtherance of its mission, the ACLU of Kentucky forms, works with and joins Coalitions of organizations and individuals collectively working on issues related to the ACLU of Kentucky’s mission of defending and preserving individual rights guaranteed by the constitutions and laws of this country (“Coalitions”). The ACLU of Kentucky does not share Voluntarily Submitted Data you submit to the ACLU of Kentucky Site with those Coalitions unless you have opted in to doing so, including by submitting Voluntarily Submitted Data to the Coalition through the ACLU of Kentucky Site or by taking an action on the ACLU of Kentucky Site that is specifically designated as an action of the Coalition (unless it states on the website page where you take such action that Voluntarily Submitted Data will not be shared with the Coalition). Once you have opted in to doing so (or have voluntarily submitted information to a Coalition in any manner other than through the ACLU of Kentucky Site), that information is information you are submitting to the Coalition itself. Unless specifically stated otherwise on the ACLU of Kentucky Site with respect to a Coalition action or a collection mechanism for a Coalition, this Privacy Statement does not address the treatment of personal information, including Voluntarily Submitted Data, that is submitted to a Coalition. Please contact the Coalition or review the privacy statement on the Coalition’s website, if it has one, to learn about the treatment of the information you provide to a Coalition.
Your Ability to Choose
When you provide us with your Voluntarily Submitted Data on the ACLU of Kentucky Site, you can let us know that you do not wish to receive our email communications by unsubscribing to email communications, by un-checking or not checking the subscription request box on the form you are completing, by un-subscribing, un-checking or not checking the subscription request box on our User Preference Page, by unsubscribing from further email communications of a specific type following receipt of an email of that type, or by contacting us via postal mail sent to 315 Guthrie St., Suite 300, Louisville, KY 40202-3820.
You can opt out of having your Voluntarily Submitted Data shared with Sharing Organizations on the online form you are filling out or thereafter by emailing us at email@example.com or by contacting us via postal mail sent to 315 Guthrie St., Suite 300, Louisville, KY 40202-3820
Again, please remember that if you are a non-U.S. resident, we will not use your Voluntarily Submitted Data for any purpose other than the one for which it was originally collected regardless of whether you check or un-check a box.
We do not knowingly collect information from children under the age of 13.
The Voluntarily Submitted Data we collect about you is stored on a secure, password protected server and only authorized personnel have access to your information. We use industry-standard encryption technologies with respect to the receipt and transfer of Voluntarily Submitted Data you submit to us on the ACLU of Kentucky Site and only authorized personnel have access to your information. Nevertheless, despite our best efforts, no transmission over the Internet and no data storage method can be guaranteed to be 100% secure.
Updating Your Data
To update your Voluntarily Submitted Data or to make corrections, you can do so by using our User Preference Page, or by sending us the update via postal mail sent to 315 Guthrie St., Suite 300, Louisville, KY 40202-3820.
Comments and Questions
If you have any questions, comments or concerns about this Privacy Statement or our data collection practices or to request that we delete your Voluntarily Submitted Data, you can email us at firstname.lastname@example.org, or send us your questions or comments via postal mail sent to 315 Guthrie St., Suite 300, Louisville, KY 40202-3820.