Effective April 3, 2020
Last updated April 3, 2020
(Note: this policy reflects the California Consumer Privacy Act as of January 1, 2020)
Collection and Use
We collect and use personal data from or about you to help us support our non-profit mission and serve our membership. We collect such data in various ways, including data you provide to us, data we collect by automated means, and data we collect from other sources.
We may share personal data pursuant to legal requirements, as necessary to protect ourselves, our members or others, or in connection with a direct or indirect reorganization process, such as a sale, merger, consolidation or bankruptcy.
We use administrative, technical, and physical security measures designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.
We strive to provide you reasonable choices regarding our collection, use, and sharing of your personal data. We provide you access to review and correct your personal data, provide you options regarding how we share personal data with third-parties, and provide you control over how we communicate with you, among other choices.
You may contact us at any time regarding these choices as follows:
- Email us firstname.lastname@example.org
- 2001 K Street, NW, Washington D.C. 20006
- Email us email@example.com
- 2001 K Street, NW, Washington D.C. 20006
Why We Collect and How We Use Personal Data
The collection and use of personal data (along with other kinds of data) helps the App Coalition to successfully advocate on behalf of the Coalition, member companies, and consumers in fulfilling its mission. We collect and use personal data from or about you to support our non-profit mission and serve our membership, including to:
- Deliver the information, programs, and/or services to you and our member companies
- Evaluate and respond to your inquiries and submissions
- Provide you with customer support in your interaction with our website or app
- Communicate with you through email, apps, and social media
- Create and manage your membership and account registrations
- Evaluate and improve our digital service, and other operations (e.g., performing market research and data analytics and assessing the effectiveness of our websites, apps, and other communications)
- Perform other business functions consistent with our non-profit mission and serve our membership
How We Collect Personal Data
Data You Provide
We collect your personal data when you choose to provide it as you interact with us through our website, app, social media and other communications. For instance, when you create an account on our website or in our app, you will be asked to provide basic personal information (such as name, address, and email address) as part of your enrollment.
Data We Collect by Automated Means
We collect data (some of which may be personal data) by automated means when you interact with us through our websites and apps, and when we communicate with you by email or text message. We use any tracking technologies, including browser cookies, Web beacons, and third-party analytics services to collect this behavioral and operational data, which may be recorded and retained in web logs and other App Coalition systems.
The collection of such data is a common practice that supports digital services and provides customized digital experiences, as well as for market research, marketing, analytics, and system administration purposes. For example, we may use this data to determine whether you’ve previously visited our website, to store your preferences and settings, and to provide authentication processes so you can more easily access your account.
Examples of the data we may automatically collect as part of our website, app, and digital communication experiences include:
- Your device and browser type, your operating system version, and your language settings
- Your Internet service provider (ISP)
- Your internet protocol (IP) address, Mobile Advertising ID, media access control (MAC) address, or similar identifiers
- The website that referred you to our website, or that you visit upon leaving our website via a link from our site
- The times and dates that you visit our websites or use our apps, and the duration of such use
- Information about areas of our websites or apps that you visited or used, as well as specific content or advertisements you viewed or links you clicked
- Information that identifies the precise physical location of your mobile device, based on your specific consent (we may use your IP address to generally estimate your location without seeking your specific consent – but such data does not provide a precise location)
- Information collected through cookies, Web beacons, analytics tools, and other similar technologies
- A “cookie” is a small data file that a website sends to and stores on your device that allows the site to recognize your browser or store information or settings. The cookie itself does not contain personal data, but can be read by the entity that placed the cookie and may allow it to associate your device to personal data. We may use “persistent” and/or “session” cookies. Persistent cookies are stored on your computer and used for various purposes by your browser on subsequent website visits (such as to avoid having to reenter your log-on credentials). Session cookies are temporarily held in your computer’s memory and erased after you end a browser session or shut off your computer.
- A Web beacon (sometimes called transparent or single pixel “GIFs”) is an invisible digital object embedded in a webpage or email. Web beacons are typically used to monitor your interaction with the webpage or email. Web beacons can help us count visitors, determine whether emails are opened, how long a webpage is viewed, and perform similar functions. Our webpages may contain Web beacons from third parties, which help us compile aggregated statistics regarding the effectiveness of our ad campaigns and assess website operations.
- Analytics tools allow us to measure and assess how users interact with our websites, apps, and digital communications.
We may also collect data (some of which may be personal data) by automated means when you call our customer service center. For instance, we may record audio of these calls for quality control, training, security, and analytics purposes.
How We Share Personal Data
We do not disclose your personal data to any third-parties except as described below. If you are a California consumer; see below in Your California Privacy Rights. We may, however, share anonymous, de-identified, or aggregate data, which cannot reasonably be used to identify you – even where it has been derived from personal data.
The App Coalition may also share your personal data with other third parties as follows:
- Pursuant to Legal Requirements. We may disclose your personal data (1) if we believe we are required to do so by law, regulation or legal process, such as in response to a court order, subpoena, or similar investigative demand; (2) as we deem appropriate or necessary in response to requests for cooperation from a law enforcement agency, taxation authority, or other government agency; and (3) to defend against legal claims, exercise our legal rights, or as otherwise required by law.
- To Protect Ourselves, Our Members, or Others. We may disclose your personal data when we believe disclosure is necessary (1) to investigate, prevent, or take action regarding illegal activity, suspected fraud, or other wrongdoing; (2) to protect and defend the rights, property, or safety of our organization, our members, our volunteers, our employees, our websites and apps users, or others; and (3) to enforce our terms and conditions or other agreements or policies.
How We Protect Personal Data
We use commercially reasonable security measures designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Despite our safeguards, however, no website, app, or information system can ever be completely secure so we cannot guarantee that the use of our systems, websites, or apps will be completely safe or secure. For additional information on privacy, identity theft, and online security, please visit the U.S. Federal Trade Commission’s website.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using our websites and/or apps, or otherwise providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of our website and app. We may post a notice via our websites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Your Personal Data Choices
Personal Data Access
If you wish to review and/or request changes to certain personal data we have collected about you (such as your current contact information, username and password, or date of birth), you may do so by logging into your App Coalition account on appcoalition.org or the App Coalition app, or by contacting us via email at firstname.lastname@example.org. In some cases, you may also have a right to (i) request deletion of certain personal data or (ii) obtain a copy of such data in an accessible format. We will make reasonable attempts to comply with such requests where applicable, but may refuse requests where we are otherwise legally required to retain the data, or the requests are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or are impractical.
Personal Data Sharing
If you would like to request that we no longer share personal data with, you may do so by contacting us via email at email@example.com. If you make such a request, it will not prevent such third-parties from using any personal data we shared with them prior to completing the opt-out process, or any data they have collected directly from you or others.
App Coalition Communications
You may choose to opt-out of some or all future communications (mail, email, phone) from the App Coalition. You can do so by contacting us at firstname.lastname@example.org. For email, you can also opt-out by clicking on the “unsubscribe” links in the footer of our emails. For phone or text messages, you can also opt-out by following the contact instructions we provide in the phone call or replying “STOP” to any text message to which you’ve previously consented. We will honor your opt-out requests as soon as practical and as required by applicable law.
Most web browsers can be set to reject cookies or provide notice when cookies are placed on your device. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. Although it is up to you whether to accept cookies from our websites, if you reject cookies, certain functions on our sites may not work properly, and your ability to use some areas of the websites may be limited.
We will request your permission before our app accesses precise location data for your mobile device, generally when you first launch our app. If you have previously consented to our app accessing precise location information, you may revoke that permission at any time through your device’s operating system location preference controls. You may also stop our access to precise location data by following the standard uninstall process to remove our apps from your device.
California Privacy Rights
Under California law, California consumers have the following additional rights:
Right to know
You have the right to request information about the categories and specific pieces of personal data we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.
You have the right to request information about our sale or disclosure for business purposes of your personal data to third parties in the preceding 12 months.
Right to delete
You have the right to request the deletion of your personal data.
Right to opt-out of sale
You have the right to opt out of the sale of your personal data to third parties. You can exercise this right through the “Do Not Sell My Personal Information” link in the footers of our websites.
Right to non-discrimination
You have the right to not be discriminated against for exercising any of these rights.
Additionally, California Civil Code Section 1798.83 permits users of the websites and/or apps who are California residents to request, once a year, certain information regarding our disclosure of personal data to third-parties for their direct marketing purposes.
If you would like to exercise one or more of the rights above, please contact us at email@example.com. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.
We may need to confirm your verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Other Important Considerations Do Not Track
We do not currently process or respond to “Do Not Track” signals from your browser. As previously described, we do participate in online advertising networks administered by third parties, which may track your online activities over time and across third-party websites.
Links to Other Websites
The App Coalition is headquartered in the United States and all of our data processing activities occur in the United States. Any personal data you provide to us, including through our websites and apps, will be transferred to, processed, and stored in the United States. By providing us your personal data or using our websites and apps, you acknowledge that the United States has standards for the processing and storage of personal data that may not be equivalent to (and may be less comprehensive than) those in the country where you reside and/or are a citizen, and you consent to our collection, transfer, processing, and storage of your personal data in the United States.
Our websites and apps are not intended for use by children under the age of 13 and we do not knowingly collect personal data from such children. If a child under the age of 13 has provided us with personal data, we ask that a parent or guardian contact us so that the personal data can be deleted.