Privacy Policy

 Last Updated: August 1, 2024

This Privacy Policy explains how Hickenlooper for Colorado (“Campaign,” “we,” or “us”) collects, uses, and discloses information about you when you access or use our websites, mobile sites, and mobile applications that link to this Privacy Policy (collectively, the “Site”). To make this Privacy Policy easier to read, our website, applications, and other offerings are collectively called the “Services.” By using our Services, you consent to the terms of this Privacy Policy.

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy, and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).  We encourage you to review the Privacy Policy whenever you access the Site or otherwise interact with us to stay informed about our information practices and the choices available to you. 

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us.  For example, we collect information when you sign up to receive updates, request information, fill out a form, sign a petition, sign up as a volunteer, sign up for an event, create an account, participate in a contest or promotion, make a donation or purchase, communicate with us via third party social media sites, request support, send us an email, or otherwise communicate with us. The types of information we may collect include your name, contact information (such as email address, postal address, and phone number), credit card and other payment information (which may be collected directly by a third-party processor), and any other information you choose to provide. 

In addition, the Federal Election Commission (FEC) may require us to collect certain personal information from donors.  For example, the FEC requires us to collect (and disclose to them) the name, mailing address, occupation, and employer of all individuals whose donations to the Campaign exceed $200 per election cycle.  

Automatically Collected Information

When you access or use our Site, we may automatically collect information about you, including:

• Log and Usage Information:  We collect information related to your access to and use of the Site, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Site.
• Device Information:  We collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Transactional Information:  If you make a donation or purchase, we may collect information about the transaction, such as donation amount, purchase price, product details, and date and location of the transaction.
• Location Information:  We may derive the approximate location of your device, such as from your IP address. 
• Information Collected by Cookies and Similar Tracking Technologies:  We (and our service providers) use different technologies to collect information, including cookies and web beacons.  Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits.  Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Site or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.  For more information about cookies and how to disable them, see Your Choices below.

Information We Collect from Other Sources

We and our service providers may also obtain information about you from other sources and combine that with information we collect about you on our Site.  

Personal Information Collected

The Colorado Privacy Act (CPA) requires us to provide some additional info to Colorado residents, which we explain below. 

The table below outlines the categories of personal information we may collect, the sources and recipients of personal information, and the purposes for which we may use personal information (depending on how and why you interact with the Services).

Personal Information Category	Sources	Purposes	Recipients
Customer Records (e.g., as name, address, telephone number, education, employment history, credit card or debit card number)	Information you provide directly or through your interactions with our Services; Third-party providers; Information from our partners	(a) Providing our Services; (b) Improving our Services; (c) Ensuring the security of our Services; (d) Providing technical support; (e) Communicating with you; (f) Enabling research; (g) Advertising; (h) Exercising/protecting legal rights and complying with legal obligations, such as federal election laws; (i) Supporting our petitions	Service Providers; Other Campaigns and Organizations with similar Political Views or Objectives.
Identifiers (e.g., real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)	Information you provide to us directly or through your interactions with our Services and Services; Information from our partners	(a) Providing our Services; (b) Improving our Services; (c) Ensuring the security of our Services; (d) Providing technical support; (e) Sharing updates and information; (f) Performing identity verification; (g) Communicating with you; (h) Advertising; (i) Exercising/protecting legal rights and complying with legal obligations, including federal election laws	Service Providers; Sales to Third Parties; Advertising Partners; Other Campaigns and Organizations with similar Political Views or Objectives.
Characteristics of protected classifications under applicable laws (e.g., your gender or age)	Information you provide to us directly; Third-party providers	(a) Enabling research; (b) Exercising/protecting legal rights and complying with legal obligations, including federal election laws; (c) Supporting our petitions	Service providers; Other Campaigns and Organizations with similar Political Views or Objectives.
Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, and information regarding your interactions with our Services)	Your interactions with our Services	(a) Providing our Services; (b) Improving our Services; (c) Ensuring the security of our Services; (d) Providing technical support; (e) Enabling participation in content offerings; (f) Communicating with you; (g) Enabling research; (h) Exercising/protecting legal rights and complying with legal obligations, including federal election laws	Service Providers; Advertising Partners;
Geolocation data	Information you provide to us directly or through your interactions with our Services	(a) Providing our Services; (b) Improving our Services; (c) Ensuring the security of our Services; (d) Providing technical support; (e) Communicating with you; (f) Enabling research; (g) Exercising/protecting legal rights and complying with legal obligations, including federal election laws; (h) Advertising; (i) Supporting our petitions	Service Providers; Advertising Partners; Other Campaigns and Organizations with similar Political Views or Objectives.
Professional or Employment-Related Information / Education information	Information you provide to us directly;	(a) Providing our Services; (b) Improving our Services; (c) Ensuring the security of our Services; (d) Providing technical support; (e) Enabling participation in content offerings; (f) Communicating with you; (g) Enabling research; (h) Exercising/protecting legal rights and complying with legal obligations, including federal election laws; (i) Advertising;(j) Supporting our petitions	Service Providers; Other Campaigns and Organizations with similar Political Views or Objectives
Inferences	Information you provide to us directly or through your interactions with our Services; Information from our partners and third-parties	(a) Providing our Services; (b) Improving our Services; (c) Ensuring the security of our Services; (d) Providing technical support; (e) Enabling participation in content offerings; (f) Communicating with you; (g) Enabling research; (h) Exercising/protecting legal rights and complying with legal obligations, including federal election laws; (i) Advertising	Service Providers; Advertising Partners; Other Campaigns and Organizations with similar Political Views or Objectives

USE OF INFORMATION

We may use the information we collect to:

• Provide, maintain, support, and improve our Site;
• Provide and deliver the information you request, process donations and transactions, and send you related information, including confirmations and receipts; 
• Respond to your emails, comments, questions, and requests and otherwise contact you about your participation in the campaign and the use of the Site;
• Communicate with you about the campaign, such as sending you information to keep you informed about various issues, events, activities, and volunteer opportunities, and provide news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time);
• To solicit volunteers, donations, and support for the Campaign and for other candidates, issues, and organizations that we support and to connect you with other volunteers;
• Contact you if Federal election laws require us to request additional information from you;
• Remind you to vote and register to vote and assist you in finding your registration information, polling location, and campaign events near you;
• Monitor and analyze trends, usage, and activities in connection with our Site;
• Personalize the Site and provide advertisements, content, or features based on your preferences, interests, and browsing and online activities;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; 
• Comply with applicable laws;
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Campaign and others; and
• Carry out any other purpose described to you at the time the information was collected.

USE OF SENSITIVE INFORMATION

Depending on how and why you interact with the Services, some of the personal information that we may collect or infer and use about you may be considered “sensitive data” or
“sensitive data inferences” under Colorado Law in certain circumstances:

• Demographic information (e.g. racial or ethnic origin);
• Religious beliefs;
• Sexual orientation; 
• Citizenship status;
• Genetic or biometrics information processed for identification purposes;
• Mental or physical health condition or diagnosis.

We only collect your sensitive personal information when you voluntarily provide this information to us and provide clear, specific, opt-in consent. If you would like us to limit or stop our use of your sensitive personal information, you may email us at [email protected]. We will respond to your request as required by applicable laws.

SHARING OF INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, service providers, volunteers, and consultants who need access to such information to carry out work on our behalf;
• With organizations, candidates, campaigns, groups, or causes that we believe have similar political viewpoints, principles, or objectives or share similar goals and with organizations that facilitate communications and information sharing among such groups;  
• With other participants in a joint fundraising committee;
• To report required information to the Federal Elections Commission, including name, mailing address, occupation, and name of employers of individuals whose contributions exceed $200 in an election cycle (for additional information, visit the FEC website at http://www.fec.gov);
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims, or legal authorities, including responding to lawful subpoenas, warrants, or court orders.
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of the Campaign, its employees, volunteers, constituents, or others;
• In connection with, or during negotiations of, any reorganization, formation of new committee or successor organization, asset sale or transfer, financing or lending transaction, or in any other situation where personal information may be disclosed or transferred as one of the assets of the Campaign; 
• With your consent or at your direction.
• The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties, provided that the foregoing does not apply to sharing (1) with vendors, consultants and other service providers who need access to such information to carry out work on our behalf (and who will not use such information for their own purposes); (2) if we believe disclosure is required by any applicable law, rule, or regulation or to comply with law enforcement or legal process; and (3) if the user consents to our sharing of such information.

We may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

LINKS TO OTHER WEBSITES

The Site may contain links to other websites.  For example, we may link to third-party sites to facilitate donations or purchases.  Any personal information you provide on such linked pages is provided directly to that third party and is subject to that third party’s privacy policy and not this privacy policy.   We encourage you to learn about their privacy and security practices and policies before providing them with personal information.  

SOCIAL SHARING FEATURES

The Site may offer social sharing features and other integrated tools (such as the Facebook “Like” button, which let you share actions you take on our Site with other media, and vice versa). Your use of such features enables the sharing of information with your friends or the public, depending your privacy for the relevant social media site.  For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications.  These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Site and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information.  This information may be used by the Campaign and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Site and other websites, and better understand your online activity.  

[For example, we may use Remarketing with Google Analytics, or other remarketing tools, to advertise online. This enables third-party vendors, including Google, to show our ads on sites across the Internet.  Such third-party vendors, including Google, may use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our Sites.  For information on how you can opt out of Google’s use of cookies for interest-based ads, please visit Google’s Ads Settings. Other advertising vendors we may use include, without limitation, Yahoo!, MSN, Facebook, and Twitter.]

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.  

TRANSFER OF INFORMATION TO THE U.S. 

The Campaign is based in the United States and is directed to U.S. residents, and we process and store information in the U.S.  If you are located outside the U.S., we, and our service providers, may transfer your information to, or store or access to your information in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

PRIVACY RIGHTS. 

Colorado residents have certain rights in respect of your personal information under the CPA. Colorado residents may not be discriminated against because you exercise your rights under the CPA. These rights include: 

• The right to know what personal information we collect about you, including the categories of personal information, the categories of sources from which the personal information is collected, the purpose for collecting or sharing personal information, and the categories of third parties to whom we disclose personal information. 
• The right to have us delete your personal information. 
• The right to correct any inaccurate personal information we may have. 
• The right to opt-out of the sale of your personal data. 
• The right to opt-out of targeted advertising online.
• The right not to have “sensitive personal data” processed unless the entity has the resident’s clear, specific, opt-in consent.

To exercise these rights, please email us at [email protected]. 

Starting July 1, 2024, you can also use a universal opt-out mechanism to communicate your opt-out choice to multiple businesses using one method. More information on universal opt-out mechanism’s, Colorado-approved universal opt-out mechanisms, and links to implement universal opt-out mechanism are available on the Colorado Attorney General’s website: https://coag.gov/uoom/.

Residents of Colorado are also entitled to request and, once a year, obtain free of charge a copy of their personal data that we hold. 

YOUR CHOICES

Account Information

You may request that we update, correct, or delete the information you provide to us by emailing us at [email protected].  We may ask that you provide certain information to verify your identity, and the information we request from you will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with Colorado Law. If we deny your request, we will explain why. Residents of Colorado have the right to appeal a Campaign decision with respect to their privacy rights. To exercise your right to appeal any of our decisions, you can respond to our correspondence providing you with our decision on your privacy right or email us at [email protected].

We may also retain cached or archived copies of information about you for a certain period of time.

Cookies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  To delete or disable flash cookies please visit www.adobe.com/products/flashplayer/security for more information.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Site.

Promotional Communications

You may opt out of receiving promotional emails or text messages from the Campaign by following the instructions in those emails or text messages.  If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device.  You can deactivate these messages at any time by changing the notification settings on your mobile device.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at [email protected]