Our Privacy Policy and Principles

[Revised 16 November 2024]

Every Citizen’s privacy is a top priority for Vote Our Way™ (VOW). In fact, because VOW’s mission is about its members and making their voice heard only in aggregate to their congressional representatives, we do not collect or permanently store any personally identifiable information, like name or birth date. We do temporarily collect voter registration information to verify that each person voting is an active registered voter in their district. And even then, its only collected for those wishing to be counted in our aggregate reports to legislators. Once we verify a Citizen is a registered voter (by comparing voter registration information against publicly known voter registration logs), any directly identifiable information is purged from our systems. This verification process usually takes less than a day but requires a purge no less then after five days regardless of our ability to verify the registered VOW member. We do also collect and use self-reported demographic and aggregated data from which we cannot directly identify with any personal information, and we maintain appropriate limits on access to data. Our internal policies and procedures conform to applicable laws and industry standards around the globe. They also incorporate the principle of Privacy by Design—a commitment to include appropriate privacy protections in the design and implementation of our tools and services.

The practices described in this Privacy Statement are undertaken by VOW as operated around the world.

We believe in responsible stewardship of data, and we are continually striving to improve our own practices and maintain high standards for our Citizen members.

VOW’s privacy principles include:

• Privacy by design
  While developing our tools and services, we assess their potential impact on personal data and embed appropriate privacy protections into our data processing activities, taking into account the other privacy principles described below.
• Trust and accountability
  We are committed to responsible stewardship of the data under our control and to compliance with all applicable data protection laws that regulate the collection, use and disclosure of data about individual people. VOW’s internal privacy team oversees compliance with applicable privacy laws, self-regulatory programs that we participate in, and our internal privacy policies. We use product design, data management tools and methods designed to exclude and prevent individuals from being identifiable in our reports and analysis, and we take steps to prevent the data we collect from being reused in ways that have not been communicated to individuals and/or could negatively affect them.

The data VOW collects
VOW only collects voting, demographic profile data and limited personal data (temporarily) where agreed from:

• Registered VOW Mobile App members – individuals who agree through the VOW Terms of Use to participate and vote on potential legislation.
• Website browsers, mobile apps and other devices that are measured by our digital and mobile products.
• Visitors to our websites and people who contact us via our websites, via email, or other means.
• Public sources – about the aggregate public and legislative activities.
• Publicly available polling data or social media – although rare and not a principal goal, we may use such data for analysis and comparison purposes.

Meaningful notice and choice
We provide clear notice about what data we collect and how we use it. We offer choices about our data collection at a time and in a context that reflect the sensitivity of the data being collected. Registered VOW Mobile App members agree to the collection and processing of the voting data they provide and may withdraw their participation at any time. Individuals also have the ability to not use our online and mobile data collection tools at any time.

Basis for processing
Many privacy laws require companies to establish a lawful basis for their uses of data. While VOW has established different lawful bases for different types of processing, in all cases our basis for processing data is in performance of our mission: VOW operates to collect and aggregate voting data on potential legislation, reporting this same voting data to legislators, measure representative legislative performance, and on occasion provides aggregate voting data to those interested in the voting voice of our members. In all cases we have consent and legitimate interest in using data.

Data minimization and collection limitation
Following the concept of data minimization, we limit the collection of personal data to the extent possible while still using non personal data enabling us to derive meaningful and accurate reporting, measurements, and analysis.

• When we use direct identifiers, we limit access to such information both internally and externally and implement appropriate data security measures, which are designed to protect individuals’ privacy.
• Before we obtain third-party data, we review the third party’s data collection practices and the privacy notices that are made available to individuals to make sure that our use of the data is consistent with the commitments those companies have made to individuals.
• When we have removed identifying elements from the data that we collect, we take steps to prevent the data from being re-associated with identifiable data.

Limited use and retention
Although we limit keeping any personal data for any long duration, we restrict access to any use of personal data in our custody to VOW personnel and service providers to only those within policy and with legitimate purpose. We have established records retention policies to limit how long we keep personal data.

Minor’s data
We do not collect minor data or allow minors to register as VOW members.

Cross-border transfer
We respect applicable local laws regarding cross-border transfers of and access to personal data.

Disclosures of data to third parties
We only disclose non-personal data with third parties, and we do not sell data that directly identifies individuals, and we contractually prohibit our clients from re-identifying individuals from the de-identified data that we provide them. Furthermore, we contractually prohibit recipients of our data from using it to make decisions regarding credit, insurance, housing, employment or other legal effects on individuals. We contractually require service providers that have access to our non-personal data to keep it secure and use it to perform only the services they have been engaged to provide. While our personal data is limited, we will provide data only under judicial warrant to government and law enforcement entities to the extent required by applicable law, to protect VOW’s legal interests and, where needed, to protect the health or safety of others.

Data security
We implement multi-layered organizational, technical and administrative measures that are designed to protect the personal data under our control. These include, among other things: limiting access to data; using technology measures like firewalls, encryption, malware protection and intrusion detection; maintaining policies that are aligned to a wide variety of legal requirements; and holding our personnel accountable for maintaining safe data-handling practices and adhering to our internal policies. We have a global organization of qualified data security professionals and engage in regular system testing and updating of our controls to keep pace with changing technology and security threats.

Our reach and local commitment
We are committed to respecting the diverse cultures and local laws of the countries in which we operate.

Contact Us.
If you have any comments or questions regarding this Privacy Policy, please contact us at VOW.Privacy@VoteOurWay.org or the mobile app developer at VOW.Technology.Apps@VoteOurWay.org.