Notice at Collection

This notice describes the categories of personal information Victory Waves Co. collects, why we collect them, and how long we keep them. It covers three different groups of people, and what applies to you depends on which group you are in.

• Customers and users — people who create an account, use our software, or contact us.
• Registered voters — people whose voter records we license from third-party data providers. If you are in this group, you have almost certainly never interacted with us, and we have no way to show you a notice at the moment of collection. That is why this page exists.
• Candidates for public office — people whose candidate filings we obtain directly from state and county election authorities, so we can tell their campaigns about our software.

Customers and users of our software

What we collect: identifiers such as name, email address, telephone number, and organization; account and authentication information; billing information processed by our payment provider; content you create in the product; support correspondence; and technical information such as device, browser, and usage data.

Why: to provide and secure the service, to bill for it, to support you, to communicate about it, and to improve it.

Sensitive personal information: we collect account credentials, which are treated as sensitive. We use them only to authenticate you.

How long: for as long as your account is active, and afterwards only as long as we need it for the purpose it was collected for or to meet a legal, tax, or accounting obligation.

Disclosure: to service providers who host, process payments for, secure, and support the product, under contracts limiting them to those purposes.

Registered voters

What we collect: identifiers including name, postal address, telephone numbers, email address, and a state-assigned voter identification number; voter registration information including party affiliation, registration status, districts, and past election participation; commercially sourced and modeled attributes including estimated household and demographic characteristics and modeled scores predicting likely views on political issues; geographic coordinates derived from a registration address; and mobile advertising identifiers.

Where it comes from: commercial voter-data providers, including L2 (Labels & Lists, Inc.) and TargetSmart Communications. Those providers obtain voter registration records from state and county election authorities and append commercially sourced information to them. We do not collect this information from voters directly. (We do obtain some records from election authorities ourselves, but for candidates rather than voters — see below.)

Sensitive personal information: some of what we license falls into categories state law treats as sensitive, including information that may reveal racial or ethnic origin or religious beliefs, and precise geolocation. Where these are modeled attributes they are statistical estimates, not statements of fact about any individual.

Why: so that political campaigns, committees, and advocacy organizations using our software can identify and contact voters — for list-building, canvassing, phone banking, petition signature verification, and related campaign activity.

How long: for as long as we hold a licence to the underlying data. Records are refreshed on a recurring basis from our providers, and suppression and opt-out instructions are applied to each refresh so that a choice you make is not undone by the next update.

Disclosure: we make this information available to our customers — political campaigns, committees, advocacy organizations, and partners who resell access to campaigns — through our software, and to service providers who host and process it on our behalf.

Candidates for public office

What we collect: your name, the office you are seeking, your committee or campaign, filing dates, and the contact information that appears on the filing.

Where it comes from: candidate filing documents published by state and county election authorities. Unlike voter data, we obtain these ourselves, directly from the authority, rather than licensing them from a provider.

Why: to identify campaigns that may want our software, and to contact them about it.

How long: for as long as the campaign is a live prospect or customer, and afterwards only as long as we need it to meet a legal or accounting obligation.

Disclosure: to the service providers that run our email, calling, and customer-relationship systems. We do not sell it.

A limit we hold ourselves to: we contact campaigns, not government offices. Where a filing lists official or governmental contact details for someone already in office, we exclude those from outreach and use campaign-side contact information instead.

What we do not do

• We do not knowingly collect personal information from children under 16.
• We do not use voter information for commercial advertising or to promote commercial products or services.
• We do not sell or share text-messaging opt-in data or consent with third parties for their own marketing.

Your choices

You can ask us to tell you what we hold, delete it, correct it, opt out of its sale or sharing, or limit our use of sensitive personal information. How to do each of those, and how long we take: Your Privacy Choices.

Full details of our practices are in our Privacy Policy. Questions: info@victorywaves.com.