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VICTORY PASSPORT


PRIVACY POLICY

Privacy Policy

Last Updated: January 1, 2018

Overview

Targeted Victory, LLC (“Targeted Victory”, “we”, “our” or “us”) provides the
following services when engaging with Victory Passport™ (“Victory Passport” or
“VP”): (1) a VP website that may be accessed at www.victorypassport.com (“VP
Site”); (2) the Victory Passport application, which provides a donation tool for
you to contribute to candidates, groups and causes (each a “Campaign”) that
matter to you using a single click anywhere you see the Victory Passport banner
(“VP application”). We provide this service through technology embedded on our
VP Contribute Site(s); and (3) VP Contribute Sites, which are websites that we
either manage, host and operate on behalf of a Campaign or own and license to
(“collectively Sites”). These Sites may provide you with certain services,
content, features and applications, including without limitation, the
opportunity to donate, create an account, request information or fill out forms
(collectively the “Services”).  For purposes of this Privacy Policy, the term
“VP Services” refers to the VP Site, VP application, and VP Contribute Sites and
Services.

This Privacy Policy explains our practices for collection, use, and disclosure
of your information, when visiting, using and/or engaging with VP Services. It
also applies to any other VP Services that link to this Privacy Policy. This
Privacy Policy does not apply to any other website operated by Targeted Victory,
any-third party websites or information collected by any third party, including
through any application or content that may link or be accessible from the VP
Services.

By using VP Services, you acknowledge that your use of the Sites and/or Services
and all information you provide in connection thereto, is governed by this
Privacy Policy and our Terms of Service. From time to time, we may update this
Privacy Policy. We encourage you to periodically check this Site for updates.
The “LAST UPDATED” legend at the top of this page indicates when this Privacy
Policy was last revised. Your continued use of the VP Services affirms your
agreement to any changes we make to this Privacy Policy.

 

CONTENTS

Voluntary Information

When you interact with us or use VP Services, Targeted Victory may collect
information about you, including “personal information.” “Personal information”
means information about you that specifically identifies you or, when combined
with other information we have, can be used to identify you.

We may collect Personal Information you voluntarily provide to us including your
name, e-mail address, postal address, phone number, mobile number, employer name
and occupation. You may provide this information when you take an action such as
registering, creating or editing a user account, contributing to a Campaign,
filling out a form, requesting information or for other purposes. As part of the
VP Services, we also may collect your credit card and billing information that
you provide to us in connection with VP Services. Additionally, we may collect
demographic information such as gender, date of birth, occupation, employer name
and zip code. We will use such information in accordance with this Privacy
Policy.

Automatically Generated Information

As you navigate through and interact with VP Services, we and our service
providers may use automatic data collection technologies to collect
non-personally identifiable information that is generated automatically while
you using the VP Services, other websites, mobile websites and/or mobile
applications or elsewhere on the Internet in order to provide content and
advertisements about goods and services of interest to you across those various
devices.

This non-personally identifiable information includes, but is not limited to,
web pages visited before and after visiting the VP Services, date and time,
logs, domain type, type of mobile device you use, your device’s unique ID links
you click on, interactions with an advertisement delivered by us or a
third-party advertising technology vendor and other communication data regarding
the resources you access and use in connection with the VP Services. We may also
collect your IP address, which is a unique identifier that certain electronic
devices use to identify and communicate with each other on the Internet.

This information is generated by the following technologies:

Cookies: This type of information may be collected using different types of
technologies, such as cookies and pixels. “Cookies” are small pieces of
information that are stored by your browser. 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 VP
Services. Unless you have adjusted your browser setting so that it will refuse
Cookies, our system will issue Cookies when you direct your browser to our
Website.  More information on how to disable Cookies is located under “Your
Choices” below.

Web Beacons: Our VP Services and our related e-mails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel
tags, and single-pixel gifs) that permit us, for example, to count users who
have visited those pages or opened an e-mail and for other related Site
statistics (for example, recording the popularity of certain Site content and
verifying system and server integrity).

Google Analytics: We use tools, including Google Analytics  – a web analytics
service provided by Google, Inc. (“Google”) – to help analyze how users use the
VP Services. This information is generated by cookies and transmitted to Google
(including IP address). This information is then used to evaluate visitors’ use
of the VP Services and to compile statistical reports on VP Services activity
for us. Google Analytics collects information anonymously. You can opt out of
Google Analytics without affecting your use of the VP Services.  For more
information about Google Analytics and to opt out of use of your information by
Google Analytics, visit Google Analytics Opt-out Browser Add-On.

 

Information Use and Sharing

Use of Personal Information

We may use your Personal Information that you submit to us via the VP Services
in order to:  present our VP Services and its contents to you;  provide you with
the VP Services or other information, products or services that you request;
provide you with information, products, or services we think might be of
interest to you; fulfill any other purpose for which you provide it; to
administer special offers from Targeted Victory or its third party providers; as
provided in this Privacy Policy or in any other way we may describe when you
provide the information and for any other purpose with your consent; provide you
with notices about your User Account, for example notifying you of reoccurring
donations; to carry out our obligations and enforce our rights arising from any
contracts entered into between you and us, including for billing and collection;
to notify you about changes to our Sites or any products or VP Services we offer
or provide; and for our everyday business purposes such as service improvements
and security, operations, fraud detection, analytics and optimization, payment
processing, and enforcement of our Terms of Use.

Submitting your e-mail address anywhere via the VP Services will result in your
e-mail address being added to the Targeted Victory e-mail list as well as the
Campaign’s e-mail list. We may use your e-mail address to contact you about our
own or a third-parties’ goods and services that may be of interest to you. We
may also use the information we have collected from you to enable us to display
advertisements to our advertisers’ target audiences. More information regarding
how to opt-out of receiving e-mails from us can be found under the “Your
Choices” section below.

 

Sharing of Personal Information

We may share your Personal Information outside of Targeted Victory if (1) you
authorize us to do so, (2) it is necessary to allow our service providers,
contractors, agents or other third parties to provide products or services for
us, such as processing payments or donations, storage, fulfillment of
promotional merchandise, distribution of e-mails, fraud prevention services,
etc., (3) it is necessary in order to provide our products or services or our
clients’ products or services to you (and contacting you when necessary), (4)
subject to applicable contractual or legal restrictions, it is disclosed to
entities that perform marketing services on our behalf or to other entities with
whom we have joint marketing agreements, (5) subject to applicable contractual
or legal restrictions, it is necessary in connection with a sale of all or
substantially all of the assets of Targeted Victory or the merger of Targeted
Victory into another entity or any consolidation, share exchange, combination,
reorganization, or like transaction in which Targeted Victory is not the
survivor, (6) it is necessary in connection with other business purposes
including, without limitation, responding to your inquiries or requests for
information or services, customer care, service quality, business management and
operation, risk assessment, security, fraud and crime prevention/detection,
monitoring, research and analysis, marketing, customer purchasing preferences
and trends, dispute resolution, credit checking and debt collection, (7) it is
necessary to disclose in order to protect or defend our rights or property or
those of our users, (8) it is necessary to disclose in order to protect the
personal safety of our users or the public, (9) it is necessary for us to
provide it to our attorneys, accountants, regulators, auditors or other
advisors, or (10) otherwise as required or permitted by law or required to
comply with legal process served upon us, our agents, clients, representatives
or our affiliates.

Use and Sharing of Non-Personally Identifiable Information

We may use Cookies to compile aggregate non-personally identifiable data about
the Sites’ traffic and Sites’ interaction so that we can offer better
experiences and tools in the future. We may also share non-personally
identifiable information with companies such as advertisers, agencies, ad
networks, or exchanges to enable them to analyze user behaviors or to customize
the ads that you encounter.

This Cookie technology is provided by our service providers, which allows us to
gather information about you, speed navigation, keep track of items and to
gather anonymous traffic data that we may use to enhance the VP Services,
marketing, and other internal purposes. We may also use non-personally
identifiable information to better tailor advertisements and other content in an
effort to create a more relevant experience for each person that visits the VP
Services or elsewhere on the Internet. This non-personally identifiable
information may also be used to predict responses to advertisements, to help
determine which ads perform best and which content is most appropriate for
different individuals, to measure and optimize the effectiveness of
advertisements, and to provide aggregate reporting to advertisers and clients
and for our and their internal purposes. We may use various website analytics
tools and technologies, including Google Analytics, regarding activities on our
the VP Services that require storage of web session data. The overall aim of
these tools is to aid in making the VP Services easy to use, to proactively
identify and correct error conditions and to provide more relevant advertising
and content to you. These tools and technologies are also used to assist
visitors who report problems in the use of our Sites and VP Services. Stored web
session data is used in accordance with this Privacy Policy.

We may disclose aggregated information about our users, and information that
does not identify any individual, without restriction, and in accordance with
applicable law.

Your Choices

E-mail

You may unsubscribe to Targeted Victory e-mails at any time by opting out of
e-mail subscriptions with the “unsubscribe” link included in each e-mail. Your
e-mail address will be removed from our marketing list. Please allow us a
reasonable period of time in order to satisfy your request, as some promotions
may already be in process.

Advertising

We, along with our third-party service providers, may use non-personally
identifiable information to provide more relevant advertising and content. You
can stop from the collection of certain types of information that provide more
tailored online ads and messages to you by clicking here.

You can also opt out and learn more information about your choices with respect
to data collection by visiting the site of the Digital Advertising Alliance,
which can be found here: http://www.aboutads.info/choices. You can also opt out
by visiting the site of the Network Advertising Initiative, which can be found
here: http://www.networkadvertising.org/choices/.

 

Disabling Cookies

You may manage how your mobile device and browser handle Cookies by adjusting
their respective privacy and security settings.  For example, the “Help” portion
of the toolbar on most browsers may also tell you how to prevent your browser
from accepting Cookies, how to have the browser notify you when you receive
Cookies, and how to disable Cookies altogether.  However, mobile devices and
browsers are different, so please refer to instructions related to your device
and browser to learn about Cookie-related and other privacy and security
settings that may be available.  Note that if you reject or block Cookies, it
may affect your ability to enjoy the full functionality and experience of our VP
Services.

 

Mobile Requests/ SMS Services

If you request to receive information to your mobile phone, you consent to
receiving communication from Targeted Victory via your mobile device. This could
include text or SMS messages. By requesting information to your mobile phone, we
may obtain the following information from you in connection with our SMS
Service: your cell phone number, your carrier’s name, and the date, time and
Content of your messages, as well as other information that you provide.

You are able to opt out from receiving SMS or text messages at any time by
texting STOP or HELP.

Please review our Terms of Use for further information regarding the SMS
Services.

Accessing Your Information

You may request that we provide you the Personal Information we hold about you,
update your information, or ask us to remove your information, or to correct any
inaccuracies in such Personal Information by sending an email to
info@targetedvictory.com. We will use reasonable efforts to deal with your
request within a reasonable time.

If you remove, update or change your Personal Information, such information may
remain viewable in cached and archived pages, or might have been copied or
stored by our third party service providers carrying out the requested Services.
Proper access and use of VP Services, is governed by our terms of use Terms of
Service.

 

Third-Party Platforms

Third-Party Links and Services

For your convenience, we may include or offer third-party offers, products,
links or services via the VP Services. Third parties may use Cookies or other
technologies to serve ads on other websites based on your visit to the VP
Services and other websites on the Internet. We cannot be responsible for the
privacy practices of any websites or pages not under our control, or how they
handle your Personal Information.  We do not endorse any of these websites or
pages, the services or products described or offered on such websites or pages,
or any of the content contained on those websites or pages. Please also be aware
that this Privacy Policy does not apply to Third-Party Sites. If you provide any
information to any third parties (e.g., social media services, payment
providers), different rules regarding the collection and use of your Personal
Information may apply. As such, we strongly encourage you to read the privacy
statements and terms and conditions of any linked or referenced websites you
enter. Nonetheless, we seek to protect the integrity of our Site and welcome any
feedback about these websites.

Social Media Platforms and other Websites

Social Networking.  Targeted Victory maintains a presence on third-party social
networking sites such as Twitter, LinkedIn, Facebook and others. Targeted
Victory does not control or have responsibility for the collection, tracking,
use, or disclosure of your information (including your Personal Information or
non-personally identifiable information) gathered through these social
networking sites, including through the Targeted Victory’s pages or profiles
within those sites, or otherwise as a result of your participation in social
networking sites. Third-party social networking sites and advertisers on these
sites, including on the Targeted Victory’s pages or profiles within these sites,
are not obligated to follow or apply this Privacy Policy or our Terms of
Service. If you have any questions about an advertisement or other targeted
content, you should contact the responsible social networking provider directly.

Social Community Features.  Any information, communications, or material of any
type or nature that you submit to our Sites (including, but not limited to any
of our pages contained on a social media platform or website such as Facebook or
Twitter) by e-mail, posting, messaging, uploading, downloading, or otherwise
(collectively, a “Submission”), is done at your own risk and without any
expectation of privacy. We cannot control the actions of other users of any
social media platform or website and we are therefore not responsible for any
content or Submissions contained on such sites and platforms. By visiting any of
our pages or websites that are contained on a social media platform or website,
you are representing and warranting to us that you have reviewed the applicable
privacy policy and terms of use of such platform or website and that you will
abide by all such provisions contained therein. Additionally, in the event that
we offer a message board or any other interactive or social-type feature on a
website administered directly by us, please be aware that these areas may allow
you to publicly post, and share with other users, certain messages, content, or
other information (e.g., stories, pictures, ingredients, tips, etc.). Although
we may take certain precautions to protect those who use these areas of one of
our websites, we encourage you to be wary of giving out any Personal Information
in such public forums. The information you post can be collected and used by
people you don’t know. We cannot guarantee the privacy and safety of these areas
and are therefore not responsible for any information you choose to post. Your
use of these features is fully at your own risk.

Suggesting the Site to a Friend

If you elect to use any feature that includes suggesting a page to a friend or
to inform a friend about VP Services or solicit donations or pledges or
otherwise communicate, Targeted Victory may ask for your friend’s name and
e-mail address. The VP Services may automatically send the friend a one-time
e-mail inviting them to visit the Sites or otherwise provide the information
requested by you. Targeted Victory will store and use this information in
accordance with this Privacy Policy. In order to refer a friend, you should
first obtain the consent from the person being referred to provide information
on their behalf and inform them that they will be receiving a communication from
us. Your friend may contact Targeted Victory at info@targetedvictory.com to
request the removal of this information from our databases.

Security

We employ and maintain commercially reasonable technology and security measures
designed to protect your Personal Information. However, no data transmission
over the Internet can be guaranteed as 100% secure. As a result, while we strive
to protect your information against unauthorized use, disclosure, alteration or
destruction, we cannot ensure or warrant the security of any information you
transmit to us or receive from us. In addition, you acknowledge that Targeted
Victory is not liable for any losses in the event your Personal Information is
revealed or stolen due to force majeure or security issues not caused by us. If
you have any questions about the security of the VP Services, you can contact us
at info@targetedvictory.com.

Your California Privacy Rights and Do Not Track Disclosures

Under California Law, California residents have the right to request in writing
from businesses with whom they have an established business relationship, (a) a
list of the categories of Personal Information, such as name, e-mail and mailing
address and the type of services provided to the customer, that a business has
disclosed to third parties (including affiliates that are separate legal
entities) during the immediately preceding calendar year for the third parties’
direct marketing purposes and (b) the names and addresses of all such third
parties. To request the above information, please contact Targeted Victory on
our Sites or write to us at (with a reference to California Disclosure
Information):

Targeted Victory, LLC
Attn: Counsel
1100 Wilson Blvd., Fl. 10

Arlington, VA 22209
E-mail: info@targetedvictory.com

We will respond to such requests for information access within 30 days following
receipt at the e-mail or mailing address stated above. If we receive your
request at a different e-mail or mailing address, we will respond within a
reasonable period of time, but not to exceed 150 days from the date received.
Please note that we are only required to respond to each customer once per
calendar year.

Like many other websites and online services, Targeted Victory does not
currently alter its practices when it receives Do Not Track signals because
there is no consensus among industry participants as to what “Do Not Track”
means in this context. To find out more about “Do Not Track,” you may wish to
visit http://www.allaboutdnt.com.

Children

You must be 18 years old to use VP Services. We strongly encourage parents and
guardians to regularly monitor and supervise their children’s online activities.
Our Sites are not intended for children under 13 years of age. We do not
knowingly collect Personal Information from children under 13. If you are under
13, do not use or provide any information on this Sites or on or through any of
its features/register on the Sites, make any purchases through the Sites, use
any of the interactive or public comment features of these Sites or provide any
information about yourself to us, including your name, address, telephone
number, e-mail address or any screen name or user name you may use. If we learn
we have collected or received Personal Information from a child under 13 without
verification of parental consent, we will delete that information as soon as
reasonably possible. If you believe we might have any information from or about
a child under 13, please contact us at info@targetedvictory.com.

Feedback

We appreciate your questions and comments about and the VP Services and welcome
your e-mails and questions. We will share your messages with those within our
organization who are most capable of addressing the issues contained in your
message. We may archive your message for a certain period of time or discard it,
but your e-mail address and message will only be used in accordance with this
Privacy Policy.

Contests, Sweepstakes and Other Promotions

You may wish to participate in contests, sweepstakes and other promotions that
we may offer from time to time. Through these promotions, you may choose to
participate in activities such as sharing information found on our Sites with
others and sending e-mail invitations. In connection with any contests,
sweepstakes and other promotions that we may offer from time to time via our
Sites, we may use the information you provide to administer the contests,
sweepstakes and other promotions. Subject to applicable contractual or legal
restrictions, we also may use the information to communicate with you, or the
other people you select, about our or our clients’ products and services or our
partners may use such information to communicate with you about the contests,
sweepstakes or other promotions or their products and services. If you choose to
participate in these promotions, and are eligible to do so, we may ask you for
information such as your name, e-mail address, date of birth and telephone
number.

Visiting from outside of the United States

The VP Services are intended for residents in the United States. If you are
visiting our Sites from outside of the United States, please be aware that your
Personal Information may be transferred to, stored or processed in the United
States, where our servers are located and our central database is operated. The
data protection and other laws of the United States and other countries might
not be as comprehensive as those in your country. By using our VP Services, you
understand that your information may be transferred to our facilities and those
third parties with whom we share it as described in this Privacy Policy. You
agree that the laws of the United States and the state of [Virginia] will govern
the processing of your Personal Information, including any obligations of
security and third-party sharing.

Contact Us

Please contact us if you have questions about our Privacy Policy
at: info@targetedvictory.com.


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 * Privacy Policy