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Online Privacy Statement
Effective as of: November 26, 2008
The American Civil Liberties Union Foundation ("ACLUF") has a long history of being at the forefront of protecting individual privacy, and we are particularly committed to protecting the personal information that you provide and entrust to us when using the ACLUF's website. This online privacy statement (the "Privacy Statement") describes how we treat all user data collected by the ACLUF during your visit to the Close Gitmo Site, both technical data that is automatically collected and voluntarily submitted data.
For purposes of this Privacy Statement, the "Close Gitmo Site" is the website whose home page is www.closegitmo.com, which is run by the ACLUF in conjunction with Brave New Foundation, a 501(c)(3) organization ("BNF"). The ACLUF also operates other websites that don't contain this domain name. This Privacy Statement does not apply to those websites (unless those websites specifically link to this Privacy Statement), including www.aclu.org, and the terms of the privacy statements for those other ACLUF websites may differ from the terms of this Privacy Statement. Additionally, this is not the privacy statement for BNF or any blogs, forums or social networking sites where ACLUF has a presence that are on websites other that the Close Gitmo Site. Further, this is not the privacy statement for the websites of any ACLUF local affiliates, and you should refer to the privacy statements on those affiliates' websites or contact those affiliates to learn the manner in which they treat information you provide to them through their websites' (or provide to them in any manner other than through the Close Gitmo Site).
The ACLUF may occasionally update this Statement. We will post any changes on this web page, so be sure to check back periodically. If we do make material changes, we will post a notice on our home page that the Privacy Statement has been modified and provide a link to the revised Privacy Statement. Any information that you submit after a change has been posted will be subject to the new provisions.
User Data We Collect
We collect two types of user data: (1) technical data that is automatically collected from all visitors to the Close Gitmo Site ("Automatically Collected Data"); and (2) data that you voluntarily submit to us (described below under "Voluntarily Submitted Data").
Automatically Collected Data. We automatically collect Internet Protocol ("IP") addresses and domain names of the originating visitor's computer on our server and may know some information you have previously provided through cookies. (See the section on Cookies below for more information.) We also track the number and frequency of hits per page by IP addresses, but we do not associate any individual IP address with any other personally identifying information except to detect security intrusions or certain unlawful activity.
In addition, if you come to the Close Gitmo Site from a website link, we may also identify the source of that link, so that we can evaluate what content is persuading web users to become involved in the ACLUF's work.
Voluntarily Submitted Data. We may collect Voluntarily Submitted Data, including personal data, that you voluntarily provide, such as your name and postal address, phone number, e-mail address, and similar information, when you participate in certain activities on the Close Gitmo Site, including (but not limited to) when you:
join or renew your membership to the ACLU;
make an additional contribution to support the ACLU;
sign up for our ACLUF e-mail network or the BNF e-mail network;
send correspondence to your government representative, to a friend or to other targeted representatives through the Close Gitmo Site;
order items from the ACLU store;
register for our message board;
register online for an event;
participate in one of our online petitions or surveys; or
participate in any activity that requires your Voluntarily Submitted Data.
Cookies
We collect some data through the use of cookies. Cookies are alphanumeric identifiers that are transferred either to your computer's hard drive ("Long-term Cookies") or temporarily to your computer's Random Access Memory ("Session Cookies").
We use Long-term Cookies only when you select a "remember" option on the Close Gitmo Site, for example the "remember my login" option offered when you log on to the Close Gitmo Site, or the "remember me" option offered on a "take action" page. If you select these options, a Long-term Cookie will be stored on your computer's hard drive solely for the purpose of automatically filling in the remembered information, for example, automatically filling in your password when you log in to the Close Gitmo Site or your postal address when you write a letter to your representative. These "remember" options are offered only for your convenience and are completely voluntary. If you do not select a "remember" option, no Long-Term Cookie will be stored on your computer's hard drive.
We use Session Cookies whenever you visit the Close Gitmo Site to run the Site's interactive applications, such as the shopping cart. Session Cookies last only as long as your session on the Close Gitmo Site. They expire when the session ends and are not written onto your computer's hard drive. We also use Session Cookies in e-mails containing the HTML-format. If you select "text-only" format preference, emails sent to you will not contain any Session Cookies.
How We Use The Data We Collect
In addition to the uses described above, we use Automatically Collected Data to identify the source of user traffic (for example, umich.edu, or aol.com), but we do not tie this information to individual users in our database. We use data on which sections of the Close Gitmo Site are most visited, so that we can evaluate the popularity of our different web pages and continue to improve the Close Gitmo Site. We do not link any Automatically Collected Data with the Voluntarily Submitted Data you provide to us except to detect security intrusions or certain unlawful activity.
We use your Voluntarily Submitted Data for various purposes:
To fulfill the request for which you specifically provided the data, including sharing the data with its intended recipient (e.g., delivering a petition you sign or a letter you wish to send to the recipient of the petition or letter, or providing data to BNF);
To periodically communicate with you concerning ACLUF matters, such as delivering to you information and updates on our activities and action alerts, if you have not opted out of receiving such information and updates;
To indicate you as the author of any comment you post, including on any Close Gitmo Site blog or forum, when you opt to identify yourself as the author or when posting such comment requires such identification, and to display any personally identifying or other information you voluntarily include in such comments.
To personalize the content that you see based on the activities and products that you have selected on the Close Gitmo Site;
To allow you to set and change user preferences;
To allow you to renew your membership in the ACLUF;
To offer you other ways to support the ACLUF, including solicitations for additional contributions if you have not opted out of receiving such communications;
To confirm your contribution to the ACLUF;
To confirm your registration to an ACLUF event;
To confirm a purchase; and
To follow up with you with an email specific to an activity you have participated in or intend to participate in.
If your Voluntarily Submitted Data includes a U.S. zip code or state and you are a member, donor or subscriber to ACLUF information, we may also share your Voluntarily Submitted Data with our local affiliate offices who may use that information to:
To periodically communicate with you concerning local affiliate matters, such as delivering information and updates on the local affiliate's activities, action alerts concerning local matters and invitations to local events, if you have not opted out of receiving that information;
To confirm your registration to an event;
To follow up with you with an email specific to an activity you have participated in or intend to participate in; and
To offer you other ways to support the ACLUF, including solicitations for additional contributions, if you have not opted out of receiving such communications.
The Close Gitmo Site is hosted by servers in the United States. Accordingly, if you are located outside of the United States, the Voluntarily Submitted Data you provide to us will be transferred to the United States. By submitting your Voluntarily Submitted Data, you consent to its transfer and storage in the United States and its use in accordance with the purposes for which it was originally collected (see below regarding third-party sharing of Voluntarily Submitted Data from non-U.S. residents).
If you are a U.S. resident, we may also from time to time combine your Voluntarily Submitted Data with some publicly available data collected from third parties to improve our services to you and for our own internal marketing, communications, and fundraising purposes.
Third Parties
Third Party Sharing
We share your Voluntarily Submitted Data with third-party service providers who fulfill your orders or transactions, contact you on our behalf, or facilitate some other aspect of the Close Gitmo Site activities, services or products, including those third-party service providers we use to assist us in our own fundraising and communications efforts and that collect Voluntarily Submitted Data on behalf of the ACLUF for the ACLUF to use as described above. These service providers have access to your Voluntarily Submitted Data solely for the purpose of providing these services to us on our behalf, and they are contractually prohibited from sharing your Voluntarily Submitted Data with any third parties (other than subcontractors assisting them in their providing these services to us and who also are contractually prohibited from sharing our Voluntarily Submitted Data with any other third parties). Please note that we do not share data from non-U.S. residents with any other third parties (except where required by law, see below), even if a non-U.S. resident has subsequently authorized such use, for example, by checking an opt-in request.
We may also share the Voluntarily Submitted Data of members and donors who are U.S. residents with other non-profit organizations and publications ("Sharing Organizations"), but never to any partisan political groups or to groups whose programs are incompatible with ACLUF policies. We never give your Voluntarily Submitted Data directly to the Sharing Organizations; instead we send the list to a third-party service provider that prepares the mailing for the Sharing Organization (and that is contractually bound to use your Voluntarily Submitted Data only for this purpose and not to share it with any third parties other than subcontractors assisting them in their providing these services to us and who also are contractually prohibited from sharing our Voluntarily Submitted Data with any other third parties). The Sharing Organizations never see our list and never know what names are on it unless you respond to the Sharing Organizations' mailing. Exchanging lists can enable the ACLUF to expand our membership base. However, if you have signed up as a member or donor on the Close Gitmo Site, you can choose to opt out of having your data shared. To learn more, read the section on "Your Ability to Choose" below.
Finally, we may disclose and use Voluntarily Submitted Data regardless of where you reside in special circumstances when it is necessary to enforce our User Agreement or this Privacy Statement, or when we, under what we hope to be extraordinary and infrequent circumstances, in good faith, truly believe that the law requires us to disclose your Voluntarily Submitted Data to third parties.
Except as described in this Privacy Statement, we will not share your Voluntarily Submitted Data with any third party unless we first notify you and offer you an appropriate choice to consent to such further use, for example, through an opt-out or opt-in request.
Third-Party Functionality
As discussed in the preceding section, to support certain functions carried out on the Close Gitmo Site, the ACLUF uses third-party service providers. In limited instances with respect to specific optional functions on the Close Gitmo Site, those third parties may have data collection, use or security procedures that differ from the practices outlined in this Privacy Statement and that may impact users of those optional functions. For example, a third-party service provider may support a specific web tool on the Close Gitmo Site, such as a web game that appears within the Close Gitmo Site, even though that tool is actually on the website of the third-party service provider. Any time a third-party service provider's data collection, use or security practices differs from the data collection/use practices described in this Statement in a manner that would impact users of the Close Gitmo Site, we will either describe on the pages of the Close Gitmo Site where such optional functions appear the specific data collection, use or security practices of such third-party service provider that would apply if you elect to use those optional functions or we will provide a link to that third-party service provider's privacy policy.
Coalitions
In furtherance of its mission, the ACLUF forms, works with and joins Coalitions of organizations and individuals collectively working on issues related to the ACLUF's mission ("Coalitions"). The ACLUF does not share Voluntarily Submitted Data you submit to the Close Gitmo Site with those Coalitions unless you have opted in to doing so, including by submitting Voluntarily Submitted Data to the Coalition through the Close Gitmo Site or by taking an action on the Close Gitmo Site that is specifically designated as an action of the Coalition (unless it states on the website page where you take such action that Voluntarily Submitted Data will not be shared with the Coalition). Once you have opted in to doing so (or have voluntarily submitted information to a Coalition in any manner other than through the Close Gitmo Site), that information is information you are submitting to the Coalition itself. Unless specifically stated otherwise on the Close Gitmo Site with respect to a Coalition action or a collection mechanism for a Coalition, this Privacy Statement does not address the treatment of personal information, including Voluntarily Submitted Data that is submitted to a Coalition. On the Close Gitmo site, you may opt to sign up for e-communications from our coalition partner Brave New Foundation ("BNF"). If you opt to do so, we will provide your information to BNF as you have requested. Please click here to review the BNF privacy statement to learn about the treatment of the information you provide to BNF through the Close Gitmo site.
Your Ability to Choose
When you provide us with your Voluntarily Submitted Data on the Close Gitmo Site, you can let us know that you do not wish to receive our email communications by un-checking or not checking the subscription request box on the form you are completing, by un-checking or not checking the subscription request box on our User Preference Page, by unsubscribing from further email communications of a specific type following receipt of an email of that type, or by contacting us via postal mail sent to Webmaster, 125 Broad Street, 18th Floor, New York, New York, 10004.
You can opt out of having your Voluntarily Submitted Data shared with Sharing Organizations on the online form you are filling out or thereafter by filling out the ACLUF Feedback Page or by contacting the Membership Department via postal mail sent to Membership Department, 125 Broad Street, 18th Floor, New York, New York, 10004.
Again, please remember that if you are a non-U.S. resident, we will not use your Voluntarily Submitted Data for any purpose other than the one for which it was originally collected regardless of whether you check or un-check a box.
Children
We do not knowingly collect information from children under the age of 13.
Security
The Voluntarily Submitted Data we collect about you is stored on a secure, password protected server and only authorized personnel have access to your information. We use industry-standard encryption technologies with respect to the receipt and transfer of Voluntarily Submitted Data you submit to us on the Close Gitmo Site and only authorized personnel have access to your information. Nevertheless, despite our best efforts, no transmission over the Internet and no data storage method can be guaranteed to be 100% secure.
Updating Your Data
To update your Voluntarily Submitted Data or to make corrections, you can do so by using our User Preference Page, or by sending us the update via postal mail sent to Membership Department, 125 Broad Street, 18th Floor, New York, NY 10004.
Comments and Questions
If you have any questions, comments or concerns about this Privacy Statement or our data collection practices or to request that we delete your Voluntarily Submitted Data, you can fill out the ACLUF Feedback Page, or send us your questions or comments via postal mail sent to Webmaster, American Civil Liberties Union, 125 Broad Street, 18th Floor, New York, New York 10004.
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