Privacy Policy

Last Modified:  August 26, 2022

1. Introduction

Welcome to the official website of Citizens for Free Enterprise (“CFE”, “Committee”, “we”, “us”, or “our”).  This privacy policy (“Policy”) explains how information is collected, used, and disclosed by the Committee so that you can make an informed decision about using our Services.  This Policy explains our practices, including the information we collect from you when you use this website, affiliated websites, and other digital, text, and online services (“Site” or “Sites”); sign up to volunteer for us; make contributions to the Committee, whether online, by mail, in person, or by other means; or participate in our events, promotions, activities, or offerings (collectively, our “Services”). 

By using the Site or Services, you consent to and agree that we may collect, process, use, retain, disclose, and transfer your Personal Information as described in this Policy. This Policy supplements and is incorporated into our Terms of Use, which may be accessed at this link or on the Site. By accessing, downloading, donating to, registering with, purchasing from, or otherwise using our Site or Services, you agree to this Policy and our Terms of Use, including any updates thereto.  We reserve the right to change this Policy or the Terms of Use at any time.  We encourage you to review this Policy from time to time to make sure that you understand how any Personal Information we collect will be used.  Your continued use of the Site or Services affirms your agreement to any changes we make to this Policy.

This Policy only applies to the information collected by us or information otherwise provided to us by third parties about you, in each instance, in connection with your use of the Site or Services.  This Policy does NOT apply to information that you provide to or that is collected by any third party.  This Policy applies regardless of the computer, phone, tablet, or other electronic device (“Device”) you use to access the Site or Services and whether you are accessing the Site or Services as a registered user, guest, or otherwise.

We take reasonable measures to protect your Personal Information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse.

2. What is Personal Information?

As used herein, the term “Personal Information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, or credit card number) and information about that individual or his/her activities that is directly linked to the individual. Personal Information does not include “aggregate” information, which is data we collect about the use of the Site or Services or about a group or category of services or users, from which individual identities or other Personal Information has been removed. This Policy in no way restricts or limits our collection and use of aggregate information.

3. Information We Collect About You

• Active Collection

Personal Information may be collected in a number of ways when you visit our Site or use our Services.  We collect certain information you voluntarily provide to us, such as when you make a contribution, send us an email or sign up to receive email or text message updates, fill out a form, connect through a social feed, submit a comment or feedback, sign up to be a volunteer or host an event, or request information.  Such information may include Personal Information, such as your name, mailing address, email address, phone number, employment information, geographic location, credit card information, and other descriptive information. We also may collect demographic information, including gender, ethnicity, date of birth, education, political affiliation, personal interest information, and social media handles. Demographic information may also be collected if you provide such information in connection with creating a profile or group, leaving comments, posting blog comments or other content, sending an email or message to another user, or participating in any interactive forums or features on the Site or through the Services. We may also obtain information from other sources and combine that with information we’ve collected on our Site and through our Services, including Personal Information we have collected about you.

To comply with Federal election law and the regulations of the Federal Election Commission, the Committee is required to make its best efforts to collect and report the name, mailing address, occupation, and name of employer for all individuals whose contributions aggregate in excess of $200 per election cycle.  Generally, contributions are non-refundable.

• Passive Collection

When you use the Site or Services, some information is also automatically collected, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring web site, and your activity on our Site.

If you access the Site or Services from a mobile device, we may also collect information about the type of mobile device you use, your device’s unique identification numbers, the type of mobile Internet browsers you use, and information about the location of your device.  We treat this information as Personal Information if it can be used to identify you individually, or if we combine it with, or link it to, any of the identifying information mentioned above. 

We may also automatically collect certain information through the use of “cookies” or web beacons. Cookies are small data files stored on your hard drive at the request of a website. Web beacons are small, invisible graphic images that may be used on the Site or in emails relating to the Services to collect certain information about usage and effectiveness and monitor user activity on the Site. Among other things, cookies and web beacons help us improve our Site and your experience on the Site and with our Services. Information obtained from cookies and web beacons and linked to personally identifying information is treated as Personal Information unless it is deidentified. If you wish to block, erase, or be warned of cookies, please refer to your device or browser manufacturer to learn about these functions. If you choose to remove or reject browser cookies or location services, however, this could affect certain features of our Site and Services.

• Third-Party Vendor Collection

At times, the Committee links to, relies on, or integrates with websites, applications, interfaces, services, and/or platforms operated by third-party companies, including service providers and third-party platforms (e.g., Google, Facebook, Twitter, etc.).  These third-parties may provide analytics services about your use of the Site, Services, or other websites to us. These vendors may also automatically collect information about your visits to this Site and other websites, including your IP address, your ISP, the browser you use to visit our Site, pages viewed, time spent on pages, links clicked, and conversion information. They do this using cookies, web beacons, clear gifs, and other technologies. Personal Information collected by these vendors may be used by the Committee and our third party partners to, among other things, analyze and track data, contact you, solicit contributions, and deliver advertising or content to you based on your prior activities. We use this information to target our communications to your interests, and to better understand the usage and visitation of our Site and Services.

In some cases, third party vendors may collect Personal Information from you, such as your name and email address, on other websites and provide this information to us through partnerships we have in place with such vendors, or we may collect Personal Information that you enter directly within an advertising unit. This Policy applies to such Personal Information collected online in this manner, to the extent it is provided to us. We will treat any Personal Information we collect in this way in the same manner as other Personal Information collected on our Site and through our Services. 

This Policy does not govern, and the Committee is not responsible for, the privacy practices of any websites, applications, interfaces, services, and platforms operated by third parties that are linked to, rely on, or are integrated with the Site or Services.  You should check the applicable privacy policy of such third-party to determine how they will handle any personally identifiable or other information they may collect from you.

4. How We Use Information That We Collect

We use Personal Information collected through our Site and Services for the purposes described in this Policy and elsewhere as may be described on the Site or Services.  The following is a non-exclusive list of how we may collect and use your Personal Information:

• Sending you CFE and affiliated committees’ marketing, promotional, or fundraising e-mails, messages (including, but not limited to, text messages), and other correspondence and notifications;

• To notify you about new features and offerings of the Site or Services, including, but not limited to, promotions, events, news, volunteer opportunities, and/or special offers;

• Delivery of features, content, services, and products available to you through the Site or Services, which at times may be based on your location;

• Allowing affiliates, service providers, contractors, agents, sponsors, and other third parties to assist us in providing and managing the Services;

• Contacting you regarding the administration of any features or functions of the Site or Services you have registered to use;

• Sending you information about your relationship or transactions with us;

• Marketing and promoting the Site or Services, including, without limitation, promotions and other initiatives and activities;

• Where you order goods or services, performing credit checks, or other authentications;

• For the prevention and detection of fraud or infringement of our or any third-party’s rights;

• Responding to your questions or requests;

• Subject to applicable contractual or legal restrictions, in connection with a sale of all or some of the assets of CFE;

• Subject to applicable contractual or legal restrictions, in connection with the sale or exchange of Site or Service user information, and related data, to a broker, political committee, or other non-profit or for-profit entity;

• Customizing what you see when you visit the Site or use the Services;

• Tracking your return visits to the Site and use of the Services;

• For marketing/promotional purposes and/or to provide anonymous reporting for Third-Party Platforms;

• Accumulating and reporting aggregate, statistical information in connection with the Site, Services, and user activity;

• Determining which features and services users like best to help us operate the Site and Services, enhance and improve our services and the Site and Services and display advertising and marketing information;

• Saving certain information for your ongoing use of the Site or Services; and

• For other purposes disclosed at the time you provide us with the information or which are reasonably necessary to provide the Services or other related product and/or service requested.

5. Sharing and Disclosure of Information We Collect

We reserve the right to use, share, exchange and/or disclose to affiliated committees and third parties any of your information for any lawful purpose, including, but not limited to, as described in Section 4.  You may choose to opt-out of certain such uses at the time such information is collected or by subsequently changing your preferences, as further described in this Policy.

For example, we may share Personal Information as follows:

• With vendors, consultants, and other service providers who are engaged by or working with us, who need access to such information to carry out their work for us, and with whom we have a contract governing their use of the Personal Information we share with them;

• With volunteers who are engaged by or working with us, who need access to such information to carry out their work for us;

• With other political or public interest organizations, groups or causes that we believe have similar viewpoints, principles or objectives (subject to applicable legal restrictions);

• When you give us your consent to share your Personal Information in a particular manner, including if you continue to use the Site or Services after we post an update to this Policy;

• 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;

• When we believe in good faith that doing so is reasonably necessary or appropriate to respond to claims or to protect the rights, property, or safety of Citizens for Free Enterprise, our users, our employees, our volunteers, copyright owners, third parties or the public, including without limitation to protect such parties from fraudulent, abusive, inappropriate, or unlawful activity or use of our Site or Services; or

• To enforce or apply this Policy or our other policies or agreements.

We are not responsible for any information you provide directly to any third parties, and we encourage you to become familiar with their privacy practices before disclosing information directly to any such parties. Nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent.

6. Opting-Out of Certain Uses of Your Information

You may be able to adjust certain privacy, permission, and user account settings by responding to request alerts or notifications that may be presented to you on your Device prior to or following the collection of the relevant information or by navigating to the settings, account, or privacy section (as the case may be) of your Device or the applicable Third-Party Platform and limiting certain service functionality (e.g., location services, etc.).  Most browsers are initially set to accept cookies and allow local storage, but you should be able to change your settings to notify you when a cookie is being set or updated, local storage is being used, and/or to block cookies and/or the use of local storage altogether. Please consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies you may not have access to certain features, content and/or other personalization available through the Site or Services.  Please be aware that if you limit the collection of certain information, you may not be able to use all of the features and functionality of the Site or Services.

Additionally, you may be presented with the option of whether to subscribe to receive, or be automatically entered to receive, certain marketing and promotional communications, including by text message, from us and/or our affiliated committees that we think will be of interest to you. Recipients of such communications may unsubscribe by following the specific instructions included in such communications.

Other privacy requests can be emailed to [email protected].  Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process, and apply, during which time your information shall remain subject to the prior privacy settings. Additionally, you should be aware that any information provided to third parties prior to your election to opt-out or unsubscribe cannot be retrieved or rescinded by us unless required by applicable law, and you cannot retroactively opt-out or unsubscribe with respect to such third parties.

Please note that in order to keep you informed about the operation of our Services and related services, we may always send you emails and announcements that are needed for the proper functioning and administration of our Services.

7. Data Collection from Minors

Our Site and Services are not intended for individuals under the age of 18. No one under the age of 18 may provide any information to, on, or through the Site or Services. We do not intentionally collect Personal Information from children. If we learn that we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe a child has provided us with Personal Information, please contact us through the means indicated below to request deletion.

8. Links to Other Websites

Our Site, Services, or messages may contain links to other websites. Any Personal Information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. This Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these websites or any other websites that are linked to our Site. We encourage you to learn about their privacy and security practices and policies before providing them with Personal Information.

9. Notice to Residents of California

Citizens for Free Enterprise is a nonprofit political organization subject to Section 527 of the Internal Revenue Code and is not subject to the requirements of the California Consumer Privacy Act of 2018 (“CCPA”).  Our collection and use of your Personal Information, however, is consistent with the Federal Election Campaign Act and the regulations promulgated by the Federal Election Commission.  Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your information for marketing purposes during the preceding year.

If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options, such as your right to opt-out (which we may sometimes refer to as “unsubscribing”) or opt-in for use of your information by third parties for marketing purposes.  If you are a California resident and wish to request information about how to exercise your third-party disclosure choices, please submit your request to [email protected].

You may request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable consumer request from you, we will delete (and direct our Contractors and Service Providers to delete) your Personal Information from our (and their) records, unless an exception applies or retention is otherwise required by federal, state, or local law.  As described in the CCPA we may delete your Personal Information by (a) permanently and completely erasing the Personal Information on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Information; or, (c) aggregating the Personal Information.

We may deny your deletion request if retaining the information is necessary for us or one of our Contractors or Service Providers to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with a legal, regulatory or law enforcement obligation; or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Upon receiving a Request from you, we will verify your identity based on the information we have on file for you. Upon verification of your identity, we will proceed to process your request (subject to the exceptions stated above).

Non-Discrimination: We will not discriminate against you simply for making a Request pursuant to this section of the Policy.

10. Notice to Residents of Nevada

If you are a Nevada resident who wishes to exercise your sale opt-out rights under Nevada Revised Statutes, you may submit a request to the contact information listed at the end of this Policy.

11. International Usage

Citizens for Free Enterprise, its Site, and Services are entirely controlled, operated, and administered within the United States of America.  If you visit, access, interact with, and/or otherwise use the Site or Services from a location outside the United States, please be advised that any information you provide in connection with any such activity may be processed in and/or transferred to the United States of America and/or other territories and locations, where privacy protections may not be as comprehensive as those in the territory or location where you interact with or otherwise use the Services. By using the Site or Services, you affirmatively consent to the transfer, use, disclosure, provision, and other administration of your information as described herein.

12. Privacy Policy Changes

From time to time, we may modify this Policy to reflect industry initiatives, third-party requirements or changes in the law, technology, our information collection and use practices, or the features and functionality of the Site or Services, and such modifications shall be effective upon posting. When we change this Policy in a material way, a notice will be posted on our website along with the updated Policy. Your continued use of the Services after we post a revised Policy (and, where appropriate, notify you of this change) signifies your acceptance of the revised Policy. It is therefore important that you review this Policy regularly to ensure you are updated as to any changes.

13. Accuracy

It is your responsibility to give us current, complete, truthful, and accurate information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful, or complete information, or you fail to update such information. We will reject and delete any entry that we believe in good faith to be false, fraudulent, or inconsistent with this Policy.

14. Retention

When you access our Site or Services, we will retain your Personal Information as long as it is necessary for our business purpose. We may retain your Personal Information for longer periods if required by law, if you give us your permission, or in case of a legal dispute in which your Personal Information may be used as evidence.

15. Sole Statement

This is the sole statement of Citizens for Free Enterprise’s Privacy Policy and no summary, restatement, or other version thereof, or other privacy statement or policy, in any form, including, without limitation, machine-generated, is valid.

16. Contact Us

If you have any questions about this Policy or any of the terms or conditions, please contact us at [email protected].