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Privacy Policy

ActionButton Privacy Policy

Effective date: February 6, 2023

Introduction

We encourage you to read this Privacy Policy to understand the information we collect, how we use it, and the choices available to you. This Privacy Policy describes the policies and procedures of Speakable PBC (“ActionButton,” “we,” “our” or “us”) on the collection, use and disclosure of your information on actionbutton.org (the “Site”) and through the services, features, content, plug-ins, widgets or applications we offer (collectively with the Site, the “Services”). We receive information about you from various sources, including: (i) your use of the Services generally; and (ii) from your use of the ActionButton on third-party websites and services.

By using the Services, you agree to this Privacy Policy and that we may process, transfer, and store your information in the United States.

This Privacy Policy contains the following sections:

Introduction
The information we collect
Cookies and similar technologies
Online analytics and advertising
How we use your information
How we share and disclose your information
Children’s privacy
Security and retention of your information
Your controls and choices
Additional information for certain jurisdictions
Changes to our Privacy Policy
Contact information

The information we collect

The information we collect about you depends on the Services you use, how you use them, and the information you provide to us.

We collect information in three main ways: (1) information you choose to provide to us; (2) information we collect automatically through technologies when you use the Services; and (3) information we collect when you use our ActionButton on third-party websites and services.

Information you choose to provide to us

When you use our Services, you may choose to provide certain information to us. For example, we collect information directly from you when you create or use an ActionButton account, post content to the Services, request information, participate in ActionButton surveys or research, or otherwise communicate and interact with us.

Some of the most common categories of information we collect from you include:

  • Contact and account information, such as name, address, telephone number, email address, and login credentials.
  • Financial and transactional information, such as credit card information will be collected and stored by our third-party payment processors. We do not store or retain your credit card information. We also collect your purchase and transaction history, if you make a purchase or a donation on the Services.
  • Donation Information, when you use the Services to make a donation to a designated 501(c)(3) charitable organization (a “Charity”), we may collect information about the amount donated. We will report the donation amount and your name (only if you provide it, you have the option to make donations anonymously) to the Charity.
  • Your questions, feedback, and requests for information, such as messages submitted to us through online forms or email.

Information we collect automatically through technology when you use the Services

When you use our Services, we may automatically collect certain information. We use a variety of third-party technologies, including cookies and similar tools, to assist in collecting this information. Please refer to the “Online Analytics and Advertising” section below for further information.

Some of the information we automatically collect when you use our Services includes:

  • Information about your access to and use of the Services and emails, such as your IP address, browser language, the state or country from which you accessed the Services, software and hardware attributes (including device IDs, operating system, and browser type), referring and exit URLs, the links you click and files you download, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our Services, the date and time you accessed our websites or opened our emails, and other similar information.
  • Location information. In addition to general location information (e.g., city/state) which may be collected or derived from your IP address, some of our Services may request your precise location information via GPS-based functionality to provide certain features of the Services to you. We will always ask your permission in accordance with your mobile device settings before we collect or use precise location information.

Information we collect from other sources

We may receive information about you from other sources, such as business partners, marketers, researchers, analysts, social network services, and other parties, to help us supplement our records.

If you choose to access the Services via a third-party log-in mechanism (e.g., your Facebook, Twitter, or Google log-in), we will collect information from those third parties in accordance with your privacy settings on their services. This information could include your name, birth date, profile picture, and similar information. If you want to limit the information shared by third parties in connection with log-in activities, please consult the privacy policies and settings of those services.

If you interact with our ActionButton through a third-party website or platform, we may receive information about how you interact with the ActionButton or the information you provide in connection with a petition or survey, such as your name, email address, message, and other information you provide. We may also collect general information about how individuals interact with our ActionButton on third-party websites and services, such as the total number of individuals to interact with our ActionButton, how frequently they interact, and how they use the ActionButton. Please note that we are not responsible for the data protection practices of third-party websites, applications, or platforms. We urge you to read the privacy and security policies of any third-party website, application, or social media platform you choose to use.

De-identified data

We may de-identify information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified form. Our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.

Cookies and similar technologies

To collect the information in the “Information we collect automatically” section above, we and our service providers use Internet server logs, cookies, tags, tracking pixels, and other similar tracking technologies. We use these technologies to offer you a more tailored experience in the future by understanding and remembering your particular browsing preferences.

  • A web server log is a file where website activity is stored.
  • A cookie is a small text file that is placed on your computer or mobile device when you visit a website, and it enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising (if any) tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
  • Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier that are designed to: (i) collect usage information like ad impressions or clicks and email open rates; (ii) measure popularity of the Services and associated advertising; and (iii) access user cookies.

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

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari).

Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

Online analytics and advertising

Online analytics. We may use third-party analytics services on our Services (e.g., Google Analytics). These service providers may set and access their own cookies, pixel tags, and similar technologies on our Services and on third-party services to collect information that can be used to track users over time and across services. These analytics services help us understand how users arrive at and use our Services. If you do not want Google Analytics to collect and use information about your use of our websites, then you can install an opt-out in your web browser.

Online advertising. ActionButton works with online analytics and advertising partners to deliver ActionButton advertisements on third-party websites and to better tailor our own ads and communications on our Services. Our partners may also place cookies, pixel tags and similar technologies on many online services, including ours. They use these technologies to collect information about your activities on these services to deliver you more relevant advertising. For example, they may use the information they collect from their cookies on our Services to recognize your device so they can show you relevant ActionButton advertisements while you are using our Services and other services.

We neither have access to, nor does this Privacy Policy govern, the cookies or other tracking technologies that may be placed on the device you use to access the Services by such non-affiliated 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 computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices 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. Please note that these opt-outs apply per device, so you will have to opt-out for each device through which you access our Services.

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set 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. Learn more about Do Not Track.

How we use your information

ActionButton may use the information we collect in the following ways:

  • To provide the services you have requested, such as complete a purchase or provide the Services to you.
  • To communicate with you, for example, keeping you posted on Services updates, and changes to our terms, conditions and policies.
  • For marketing and advertising purposes,including providing you with relevant announcements, promotions, and information about upcoming events.
  • To personalize your experience and customize the Services, such as delivering relevant content and recommending features through our Services.
  • To improve our Services, including bug detection and error reporting, to understand how users interact with our Services and advertisements, improve usability and effectiveness of our products, perform research and analytics, and to test and create new features and services.
  • For our business operations, including maintaining your account, and for security, fraud prevention, and legal compliance, such as detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
  • Other purposes for which we seek your consent. We may also use your information for a specific purpose that we communicate to you. We will ask for your consent to process your information for such purpose in accordance with applicable legal requirements.

The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information.

Our legal bases for processing your information as described in this Privacy Policy are as follows:

  • Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the services you’ve requested from us, or to comply with our Terms of Service.
  • Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate our business and our Services, make and receive payments, defend our legal rights, and prevent fraud.
  • Where we use your information to comply with applicable legal obligations.
  • Where you have consented to our processing of your information for a particular purpose.

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

How we share and disclose your information

ActionButton may share your information in the following ways:

  • Affiliated entities. We may share information within the ActionButton family of companies to deliver the Services, operate our business, and enhance our Services and your customer experience.

  • Service providers. We use select third-party vendors to help us provide our Services and operate our business, and we may provide access to or share your information with these vendors. They provide a variety of services to us, including payment processing, data storage, security, and fraud prevention. These service providers are permitted to access and use your information for purposes of performing services for ActionButton.

  • Charities. If you make a donation through the Services, you agree that we may share information about your donation (including your name if you did not make the donation anonymously) with the Charity. The Charity will use your information in accordance with its own privacy policies and terms, so please review these documents on the websites of the Charities to which you donate.

  • Protection of ActionButton and others. We may disclose the information we collect about you if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (for example, a subpoena or court order) but we will inform you first, if we are permitted to do so; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of ActionButton, its employees or others.

  • Business transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, including in contemplation of such transactions, your information may be among the transferred assets. If a portion or all of ActionButton’s assets are sold or transferred to a third party, we may share or transfer your information as part of the transaction.

  • Consent. We may also share your information in circumstances where we have your consent to do so.

Children’s privacy

Our Services are intended for general audiences and are not directed at children. If we become aware that we have collected data without legally valid parental consent from children under an age where such consent is required, we will take reasonable steps to delete it as soon as possible.

Security and retention of your information

Security of your information. We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. If you create an account on the Services, it is important that you select a strong password and do not share it with others. Alert us immediately if you have any concerns about unauthorized use of your account.

Retention of your information. We retain information for different periods of time depending on the purposes for which we collect and use it, or in accordance with our legal obligations, as described in this Privacy Policy.

Your controls and choices

We provide you with the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information. Your legal rights to exercise such controls and choices vary based on the laws of your jurisdiction.

You may request the following by contacting us using the information in the “Contact Us” section below:

  • Access to, or a copy of, your information
  • Correction or amendment of your information
  • Deletion of your information
  • Transfer of your information to a third party
  • Restriction or objection to certain uses of your information

We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests.

Marketing Opt-Out. You can opt-out of marketing emails from ActionButtonby following the instructions located at the bottom of our email marketing messages. Please note, opting-out or unsubscribing will not prevent you from receiving transactional communications about the Services, or other important notices such as changes to our terms and policies, which are not marketing in nature.

Additional information for certain jurisdictions

Information for California residents

If you are a California resident, California law requires us to provide you with the following additional information about the purpose for which we use each category of “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)) we collect. For information about each category and purpose of use, please see “The information we collect” and “How we use your information” sections above.

The CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. Based on the definition of sell under the CCPA and under current regulatory guidance, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.

To exercise any rights you may have with respect to your personal information under California law, please see the “Your controls and choices” section above. We will not discriminate against you for exercising these rights.

California “Shine the Light” disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt-out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. Please contact us using the information in the “Contact Us” section below if you’d like to understand more about the applicability of this law to ActionButton and make a request.

Information for Nevada residents

Under Nevada law, certain Nevada consumers may opt-out of the sale of “personally identifiable information” for “monetary consideration” (as such terms are defined under Nevada law) to a person for that person to license or sell such information to others. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt-out of any future sales under Nevada law by contacting us as detailed in the “Contact Us” section below. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

Information for international users

We are located in the United States and may transfer, store, and/or process your information to or with other entities within the ActionButton family of companies or other third parties such as trusted service providers and partners in the United States for the purposes described in this Privacy Policy. Wherever your information is transferred, stored, or processed by us, we take reasonable steps to protect your information in accordance with this Privacy Policy and applicable laws. By providing us with your information, you acknowledge any such transfer, storage, or processing.

EU-U.S. Privacy Shield Framework

ActionButton complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union to the United States. ActionButton has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, ActionButton commits to resolve complaints about our collection or use of your personal data. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact [email protected].

ActionButton has further committed to refer unresolved Privacy Shield complaints to the JAMS Privacy Shield Dispute Resolution Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of the JAMS Program are provided at no cost to you.

As part of the Privacy Shield Framework, ActionButton is subject to the investigatory and regulatory enforcement powers of the U.S. Federal Trade Commission. Under certain conditions, described here, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

ActionButton sometimes transfers personal data to a third party for the purposes of sub-processing. When we do make such transfers, we limit them as follows: (i) we transfer data only for limited and specified purposes, consistent with the consent you have provided; (ii) we ensure that the sub-processor is obligated to provide at least the same level of privacy protection required by the Privacy Shield Principles; (iii) we take reasonable and appropriate steps to ensure that the sub-processor effectively processes the personal information transferred in a manner consistent with our obligations under the Privacy Shield Principles; (iv) we require the sub-processor to notify us if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles; (v) if we receive such notice, we take reasonable and appropriate steps to stop and remediate any unauthorized processing; and (vi) we agree to provide a summary or a representative copy of the relevant privacy provisions of our contracts with sub-processors to the Department of Commerce upon its request.

In the context of an onward transfer to a third-party sub-processor, ActionButton remains responsible for the processing of personal information it receives under the Privacy Shield if the sub-processor processes such personal information in a manner inconsistent with the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

Changes to our Privacy Policy

From time to time, we may change or update this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. You should review the Privacy Policy periodically to determine if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective date” at the beginning of the document. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. If we make material changes to the Privacy Policy, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective, in accordance with applicable legal requirements.

Contact Us

If you have any questions or concerns regarding privacy using the Services, please send a detailed message to [email protected] or to [email protected]. We will make every effort to resolve your concerns. You can also write to us at:

Speakable PBC
PO Box 811785
Los Angeles, CA. 90081