VOTE FROM ABROAD PRIVACY POLICY
Last updated May 10, 2022. Replaces all prior versions.
Vote from Abroad (VFA) is a public service provided by the Democratic Party Committee Abroad, doing business as Democrats Abroad (also known as “DA”). Democrats Abroad — the official Democratic Party organization for millions of Americans living outside the United States — is committed to protecting the privacy and security of your personal information. We collect different types of information from you when you use our web-based services (“Services”), as defined further below. This Privacy Policy will help explain what information we collect, how we use it and what options you have in relation to it. To fully understand your rights and obligations related to your use of our online Services, please read our Terms of Service. The key points of our Privacy Policy are provided in the summary below. However, you can also learn more by simply following the links below or by continuing to scroll down.
Privacy Policy Summary
VFA is a nonpartisan public service. VFA is a nonpartisan voter registration and overseas ballot request service available to all eligible overseas United States citizens and military voters. Our Services are nonpartisan because we will not withhold or refuse to provide our Services to anyone on the basis of support for or opposition to particular candidates, or on the basis of party affiliation (or non-party affiliation). We want you to exercise your right to vote as an American citizen regardless of your party affiliation or lack thereof. We only ask about your party affiliation (i) to complete your voter registration or ballot request materials (“voter materials”) to the extent required by state law or (ii) as a part of an optional survey to better understand the needs and characteristics of overseas voters. A third situation in which we indirectly ask you about party affiliation is discussed in the fourth paragraph of this Privacy Policy Summary (addressing the “opt-in” feature), as well as in Section 5 (“What happens to my personal data if I ‘opt-in’ to joining Democrats Abroad”), below.
Our Services The VFA site offers a variety of nonpartisan voter registration and get-out-the-vote services (“Services”) including, but not limited to: (a) state-specific voter registration information (including voter registration, ballot request, and ballot submission deadlines); (b) state-specific voter eligibility requirements as prescribed by law; (c) information on the names and addresses of local election officials (LEOs); (d) state-specific information on the legally accepted means to transmit your voter materials to your LEO; (e) access to our voter material preparation tool that allows you to quickly, easily, and accurately prepare your voter materials online and either (1) direct VFA to submit your forms by email to your LEO or (2) download and print your voter materials if your state requires submission by fax or postal mail; (f) access to our Voter Help Desk for customer service inquiries to answer questions about overseas voting; and (g) any other services identified in our Terms of Service.
No transfer of your information without consent As we provide these Services to you, we want you to know that we are committed to protecting your privacy online. Any information you provide through the VFA website will be handled with the utmost care and with appropriate security measures in place that protect the confidentiality of your personal information. We do not transfer your data to commercial data brokers or to other political entities such as the Democratic National Committee (DNC), the Democratic Congressional Campaign Committee (DCCC), or the Democratic Senatorial Campaign Committee (DSCC). When you grant us permission to do so, we will submit your voter materials to your LEO by email, and we will copy you on the email correspondence using the email address you provide to us. You consent to this transfer of your personal information by clicking the “SEND EMAIL” button as the final step of our online voter material preparation tool. Please note that this transfer only applies to voters in states that permit the submission of applicable voter materials by email. If your state does not permit you to submit your voter materials by email, you will need to download and/or print the forms generated using our online tool and send them to your local election official (LEO) via postal mail, or by fax if permitted. If you have any questions about this process, please contact the VFA Voter Help Desk at help@VoteFromAbroad.org.
Understanding the “opt-in” feature The VFA website has a feature called the “opt-in,” and we want to be very clear about what that means. The “opt-in” is an option you can select while using VFA’s voter material preparation tool. The option appears during the process of completing your voter materials whether or not you have a Voter Account, and it allows you to join Democrats Abroad or update and verify your existing membership. You will be asked, “Would you like to join Democrats Abroad?” You may respond “Yes,” “No,” or “Already a member.” It is important that you understand you are under no obligation whatsoever to select this option in order to use VFA’s Services, and doing so in no way impacts the Services you are offered when using VFA. However, if you select “Yes” (to join Democrats Abroad), you are granting your affirmative consent to join Democrats Abroad, in which case you are also consenting to permit the VFA database, which is owned and operated by Democrats Abroad, to transfer your personal data and preferences to the Democrats Abroad membership database. For more information on the “opt-in,” see Section 5 below.
Use of your information Unless you opt-in to membership in Democrats Abroad (in which case, see Section 5), we will not use any information provided to us here for any purpose other than in connection with the preparation and submission of your voter materials or to ensure our database is functioning properly. Also, we use aggregate information about our users for statistical reports, but it will not be possible to identify you from such reports. We use those reports to determine the number of VFA users, where they reside, where they vote, etc. We will not disclose your information to third parties for any other purpose unless we first obtain your consent, except as required by applicable law or regulation.
How your information is stored and shared Any information that you provide through the VFA website will be collected and transferred to a database stored on a secure server maintained by Democrats Abroad in the United States of America. Thus, if you are located outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States; by using our website and giving us your information, you consent to such transfer. When you provide information using the VFA voter material preparation tool, your information will automatically be deleted ninety (90) days after the date of the next federal United States general election.
GDPR Notice (Users residing in the EU) The US citizen users of our website reside in countries around the world. As a portion of our users reside in the European Union (EU), this privacy policy and our online practices are designed to comply with the EU General Data Protection Regulation (GDPR). We are committed to providing you with a very high level of privacy protection, and this privacy policy is the same for all visitors and users of our website, regardless of where they reside. You should be aware, however, that applicable laws and regulations protecting personal information in the United States may not offer identical protection as provided in other jurisdictions, including those that belong to the European Economic Area.
Questions If you have any questions about our privacy policy, the information we have collected from you online, the practices of this site or your interaction with this website, please send an email to: privacy@democratsabroad.org. You may also contact us directly by US mail at Privacy Internet Operations Division, Democrats Abroad, PO Box 15130, Washington DC, 20003, USA.
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Introduction
This Privacy Policy explains how we collect, use, and protect your personal information when you use our Services. By using our Services you acknowledge that you have read and understood the terms of this Privacy Policy, including how we use your personal information. Democrats Abroad, as the data controller, is responsible for collecting and using your personal information. See the “Your questions and how to contact us” section of this Privacy Policy (Section 9) for more details.
We reserve the right to update this Privacy Policy from time to time by changing it as it applies to your use of any of the Services, but we will provide you with reasonable notice of any material changes that limit or restrict your ability to control your own data. The date of the current Privacy Policy is the Effective Date set out above. Regardless of party affiliation, we provide our Services to make overseas voting easier and to offer personal voting assistance to answer your questions and to help you ensure that your ballot is received and counted. We urge you to follow common sense whenever disclosing personal information – in connection with our Services or elsewhere.
1. Legal basis for collecting your personal information
When we collect and process personal information from you, your consent and agreement to abide by our contractual terms establish the primary legal basis for doing so:
(i) When you browse our public website, you consent to our collection of personal information by agreeing to this VFA Privacy Policy, the VFA Cookie Policy, and our Terms of Service as they apply to browsing;
(ii) When you use our online voter material preparation tool, you consent to our collection of personal information by agreeing to this VFA Privacy Policy, the VFA Cookie Policy, and our Terms of Service as they apply to browsing and accessing our Services; and
(iii) Other legal bases for collecting and processing your personal information include:
a. Compliance with legal obligations to which Democrats Abroad is subject;
b. Legitimate interests of Democrats Abroad, provided that such legitimate interests do not interfere with other fundamental rights and freedoms you possess.
If you live in the European Union and we have obtained your personal information but you did not provide it to us, then we will provide you with a copy of this Privacy Policy and any other information required by law at the time of our first communication to you or within 30 days after receiving your information, whichever occurs first.
2. Information we collect and receive
We collect personal information about you and the devices you use to access and interact with us and our Services. We collect:
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(a) Voter registration information: |
Information you give us when you use our voter registration or voting assistance Services without establishing a Voter Account |
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(b) Technical and device information: |
Information (including country information) from your mobile or computer device when you use our Services |
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(c) Feedback: |
Your questions, suggestions or views on our Services |
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(d) Third party information: |
Information about your use of our Services that is shared with third party platforms and services connected with our Services |
(a) Voter registration information
When you use our Services to register to vote or request your ballot, we collect information about you necessary for completing your Federal Post Card Application (FPCA) form. This information includes your full name, status as a citizen of the United States of America, information on whether you are residing overseas temporarily, indefinitely, etc., email address, telephone number, date of birth, residential address abroad, voting address in the United States, personal preferences and additional information that you choose to provide. We may also ask for your consent to receive communications from VFA in connection with VFA’s Services.
Some states require voters to provide sensitive personal information when registering to vote or requesting an absentee ballot. Sensitive personal information includes information such as driver’s license numbers, Social Security Numbers or the last four digits thereof, political party affiliation information, an electronic image of your signature, etc. Even if you provide this information while using our services, we do not store this information and have no access to this information through our VFA database. For privacy and security purposes, unique web links provided to download completed forms expire shortly after they are created, and, except for our copy of the email you authorize to be sent to your LEO through the VFA website, neither the links nor any other copy of your completed forms are stored or otherwise retained by Democrats Abroad.
Please note that we do not control the information that is sent from your browser to third parties, including social media platforms, analytics companies, and advertising networks which receive information in the normal course of your online activities.
(b) Technical and device information
By accessing our Services, we may use technical information from your mobile or computer device to, for example, auto-select your country as inferred by your Internet Protocol (IP) address, or understand which devices are connected to the internet, hardware settings, components of your devices, installed software, updates and plugins to facilitate the use of our Services. We may automatically collect information such as your operating system, IP address, your browser type, browser language preferences, and when, how often, and how long you interact with our Services. We and/or third party services use cookies and similar technologies. See also our Cookie Policy.
(c) Feedback
When you browse or otherwise use the VFA website, we collect information about the way you use our Services. We may also collect information about you from the notifications or messages you post or send online as well as what you search for, look at and engage with. Information obtained from social features used in connection with our online Services, such as forums and chat functionality, may be stored, copied, or used by Democrats Abroad, the public, or third-party companies. We will collect personal information from the messages and reviews you post on our social forums and when you contact our Help Desk at help@VoteFromAbroad.org, for example, with a question, problem, or comment. If you contact our customer services team by email or post, we will keep copies of your correspondence with us to handle your query. For more information, see section 2(d), below, on how we use third party information.
(d) Third party information
We may share information obtained from your use of our Services with third parties to provide you with an optimal experience, to facilitate use of the Services, and to enable you to use our Services on various platforms (e.g., social networking services, etc.).
3. How we use the information we collect
We may use the information we collect from you in the following ways:
(a) Voter registration information
You may use our Services to prepare or submit your FPCA or FWAB forms. The information we collect (see Section 2(a), above) will not be used for any purpose other than (1) preparation and submission of your voting materials; (2) to ensure our database is functioning properly, such as (i) fixing errors in our VFA and Democrats Abroad databases and (ii) determining whether the bridge between the VFA database and the Democrats Abroad database is functioning properly; (3) responding to customer service inquiries; and (4) the preparation of statistical reports using anonymized, aggregated information about our users (it will not be possible to identify you from such reports). We use those reports to determine the number of VFA users, where they reside, where they vote, etc. We will not disclose your information to third parties for any other purpose unless we first obtain your consent, except as required by applicable law or regulation. For more information on how long we retain your personal information, see Section 6 on data retention.
(b) Technical and device information
(i) to provide you with an optimal experience;
(ii) to understand how you interact with our Services;
(iii) to provide Services you request;
(iv) to measure and analyze the use and effectiveness of our Services;
(v) to understand which of your devices are using our Services;
(vi) to provide a safe and fair online environment in connection with our Services;
(vii) to measure and analyze the use and effectiveness of our Services;
(viii) to customize and optimize the targeting of our advertising in connection with our Services and across other websites and Services;
(ix) to operate and improve our Services; and
(x) to fix errors.
We analyze information about how you engage with our Services to understand how our Services are used and to provide you with an optimal user experience. We use anonymous data in order to analyze and produce statistics relating to the habits, usage patterns, and demographics of users as a group or as individuals. This allows us to deliver you personalized content, helps us understand the features of our Services that appeal to you, and allows us to manage our communications strategy, among other things.
When you interact with or visit our websites, we may automatically collect information about you such as the type of internet browser or mobile device you use, any website from which you have come to the VFA website, and your IP address (the unique address which identifies your device on the Internet) and your operating system, which are automatically recognized by our web server. We use internet log files to monitor traffic related to our Services, resolve technical problems, and to detect and prevent fraud. We use these technologies to provide us with information, such as when an email is opened, or to develop statistics on the effectiveness of communication with you on or through our website. In some cases, we use this information to send you communications based on your interests. We also use technical and device information to operate and improve our Services, measure our effectiveness, set up and maintain accounts, identify and fix errors, help keep online content fair and safe, and to resolve related disputes.
(c) Feedback
(i) to reply to your questions or queries;
(ii) to record comments and information which you provide via our website or other forums we provide; and
(iii) to conduct analysis and research to improve and develop our Services.
We use your feedback to reply to your questions or queries, to provide customer support, and resolve problems relating to any of our Services under the agreements that we have with you. We may also publish reviews that you submit to us for this purpose about the Services and may conduct analysis of feedback for the purpose of improving and developing our Services.
(d) Third party information
(i) to facilitate sharing on social networks; and
(ii) to enhance your experience when using our Services.
Based on your affirmative consent, we share information obtained from your use of our Services with third parties to provide you with an optimal experience, to facilitate use of our Services, and to enable you to share our content on various platforms. For example, our website may allow you to share our content via email, Facebook, Twitter, etc. To enable this functionality, we may share your information through the websites and services of third parties and/or use cookies which are stored on your device. See also our Cookie Policy.
4. When we share information
We do not sell, or otherwise share, the information we collect about you to commercial data brokers or anyone else (subject to the necessary security, contractual and transfer safeguards). We do not provide your data to other political entities such as the Democratic National Committee (DNC), the Democratic Congressional Campaign Committee (DCCC), or the Democratic Senatorial Campaign Committee (DSCC). However, there are some very limited exceptions in which we provide access to your personal information by certain individuals or organizations, as follows:
When you grant us permission to do so, we will submit your voter materials to your LEO by email and we will copy you on the email correspondence using the email address you provide to us. You consent to this transfer of your personal information by clicking the “SEND EMAIL” button as the final step of our online voter material preparation tool. Please note that this transfer only applies to voters in states that permit the submission of applicable voter materials by email. If your state does not permit you to submit your voter materials by email, you will need to download and/or print the forms generated using our online tool and send them to your LEO via postal mail, or by fax if permitted. If you have any questions about this process, please contact the VFA Voter Help Desk at help@VoteFromAbroad.org.
Executive officers and information technology professionals of Democrats Abroad VFA is directly owned and operated by Democrats Abroad. Accordingly, executive officers and selected IT professionals have access to information collected and processed through VFA. These individuals are all subject to confidentiality agreements.
As explained in the Privacy Policy Summary and in Section 5 below, personal information collected by VFA is only transferred to the Democrats Abroad membership database if the user affirmatively “opts-in” to joining Democrats Abroad by clicking the appropriate box during VFA’s voter registration/ballot request application process. These “opt-in” members are subject to the Democrats Abroad Privacy Policy, available at: https://www.democratsabroad.org/privacy.
We may use or share the information that you provide if we are under a duty to disclose your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or to enforce the relevant terms of service and any other agreement; or to protect our rights or the rights of third parties. This includes exchanging information with other companies and organizations such as credit agencies, law enforcement or government bodies, or the courts in connection with a criminal investigation, suspected illegal activity, fraud prevention and detection, or in legal proceedings.
We do not control information which is sent from your browser to third parties, including social media platforms, analytics companies, and advertising networks that receive information in the normal course of your online activities.
Personal information may be transferred to or routed through servers in other countries where Democrats Abroad or its service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access the Services or, in the case of transfers subject to European law, may not be subject to an adequacy decision by the European Commission (EC). An adequacy decision is a decision taken by the EC establishing that a third country provides a comparable level of protection of personal data to that in the EU, through its domestic law or its international commitments.
If it becomes necessary for Democrats Abroad to transfer your personal information to a third party, it will seek to take account of any applicable legal obligations relevant to personal information transfers. In the case of transfers of personal information out of the European Economic Area, it will, in the absence of an EC adequacy decision relevant to the destination country, seek to rely on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient - https://www.privacyshield.gov/welcome) or enter into appropriate EC approved standard contractual clauses relevant to personal data transfers between data controllers or between a data controller and a data processor (http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm).
5. What happens to my personal data if I “opt-in” to joining Democrats Abroad
Joining Democrats Abroad Using the “Opt-in” Feature The VFA website has a feature called the “opt-in,” and we want to be very clear about what that means. The “opt-in” is an option you can select while using VFA’s voter material preparation tool (see the image below). The option appears during the process of completing your voter materials and it allows you to join Democrats Abroad or update and verify your existing membership. You will be asked, “Would you like to join Democrats Abroad?” You may respond “Yes,” “No,” or “Already a member.” It is important that you understand you are under no obligation whatsoever to select this option in order to use VFA’s Services, and doing so in no way impacts the Services you are offered when using VFA. However, if you select “Yes” (to join Democrats Abroad), you are granting your affirmative consent to join Democrats Abroad, in which case you are also consenting to permit the VFA database, which is owned and operated by Democrats Abroad, to transfer your personal data and preferences to the Democrats Abroad membership database.
Figure 1: Screenshot of the Democrats Abroad “Opt-in” (“Would you like to join Democrats Abroad?”)
By joining Democrats Abroad, you consent to Democrats Abroad’s:
(i) Privacy Policy (https://www.democratsabroad.org/privacy);
(ii) Cookies Policy (https://www.democratsabroad.org/cookies);
(iii) Terms of Service;
(iv) and being contacted by Democrats Abroad (see below on adjusting communications preferences).
An account with Democrats Abroad will automatically be set up for you upon submission of your opt-in request. You may adjust your Democrats Abroad communications preferences by logging into your personal membership account at https://democratsabroad.nationbuilder.com/login.
Please note that you do not need to click the opt-in button to join Democrats Abroad. You can join separately by visiting https://www.democratsabroad.org/join.
6. Security, storage and data retention
Security Your privacy is important to us and we place great importance on the steps we take, including technical and organizational measures, to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.
Storage Any information that you provide through the VFA website will be collected and transferred to a database stored on a secure server maintained by Democrats Abroad in the United States of America. In other words, when you input data into VFA, you authorize your data to be directly saved to a server in the United States of America. This information is collected and stored by Democrats Abroad. Thus, if you are located outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States; by using our website and giving us your information, you consent to such transfer. When you provide information using the VFA voter material preparation tool, your information will automatically be deleted within ninety (90) days following the next federal United States general election, unless we have identified or are informed of a legal reason to maintain your information (in which case we will delete your information within a reasonable time after the aforementioned legal reasons no longer exist).
Retention Data retention will differ according to the way you choose to use our Services.
(a) Browsing Except for the collection of technical and device information (see Sections 2(c) and 3(c), above) and the preparation of voter materials, all users of the VFA website can browse and use our Services without entering personally identifiable information into the VFA database.
(b) Preparation of Voter Material You can use our Services to prepare voter material. Your information will not be permanently stored on our server, as it will be automatically deleted within ninety (90) days following the next federal United States general election, which is routinely scheduled for the Tuesday following the first Monday in November in even numbered years. This information will be retained for the purposes of (1) responding to any customer service inquiries lodged during the election cycle, (2) determining whether the bridge between the VFA database and the Democrats Abroad database is functioning properly, and (3) preserving records connected with voter material for a reasonable time after any election challenge may be filed. Following the “Election plus 90” retention period, all records subject to this paragraph will be permanently deleted, unless prohibited by law, court order, legal right or obligation, etc.
(c) “Opt-ins” In addition to the applicable retention period referenced above, if you “opt-in” to membership in Democrats Abroad, you consent to Democrats Abroad’s retention of your personal information transferred to the Democrats Abroad membership database. In that case, your personal information stored in the Democrats Abroad membership database will be subject to the terms of the Democrats Abroad Privacy Policy (https://www.democratsabroad.org/privacy), and your personal information stored in the VFA database will be subject to this VFA Privacy Policy.
(d) Records of your objections We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving communications from the VFA website. We will do this for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further during the term of your objection. We will take appropriate steps to seek to destroy or permanently de-identify personal information at the point this information is no longer needed by us for our business or legal purposes. For more information about exercising your rights with respect to our data processing activities, or if you no longer wish to use our Service, see below for details on your choices and rights.
(e) Other For any other category of user not addressed in paragraphs (a) through (d) above, your personal information will be retained by us for the duration of your use or access to our Services and may be retained for a period after this time as necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws and obligations. This may include retention necessary to meet our tax or Federal Election Commission (United States) reporting requirements as well as time required to enforce any obligations in our agreements, or to identify, issue or resolve legal proceedings.
7. Your choices and rights
You have options and choices over how we use your personal information. Based on our Terms of Service, you agree to receive communications from us. You may inform us via the Help Desk if you no longer wish to receive communications from us, and if you do receive a communication, you will be given the opportunity to unsubscribe.
You have options and choices over how we use your information. We provide you with tools to access and update specific information relating to your use of the Services at any time.
We respect the rights you may have under applicable law to request access to your personal information and where applicable, to request and receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party where feasible). You may also have the right under applicable law to request the correction or erasure of your personal information, to object to further processing of your information, or to request that the processing of specific information about you is restricted while we verify or investigate your concerns about this information.
If you remain unhappy with a response you receive, you can also refer the matter to your data protection supervisory authority. If you reside in the European Union, see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
8. Children’s information
United States citizens must be 18 years old or over to be eligible to vote. This means that most people who use the VFA website to register to vote are18 years old or older. However, any United States citizen may register to vote if he or she will be 18 or older on the date of the next federal election. Because federal elections occur every two years, it is possible for a 16-year-old to complete and submit voter registration forms to their local election officials; thus, it is possible that we may collect information on individuals who are 16 years old.
Because voter registration laws vary from state to state, we encourage all eligible voters to submit their voter registration and/or ballot request applications as soon as possible in January of each calendar year.
Protecting the privacy of young children is especially important to Democrats Abroad. For that reason, we do not knowingly collect or maintain personal information or non-personally identifiable information from users under 16 years of age, other than as permitted by law in support of our internal operations. If we learn that personal information of users under the age of 16 has been collected, Democrats Abroad will take reasonable steps to remove such information. If you believe that we may have unintentionally collected personal information about your child who is under 16 years of age, you may contact us using the details provided below.
9. Your questions and how to contact us
If you have any questions or comments about this Vote From Abroad Privacy Policy, you can contact us.
By email at: help@democratsabroad.org
By writing to us at:
Data Protection Officer
Democrats Abroad
PO Box 15130
Washington DC, 20003
United States of America
You can also contact our Data Protection Officer at dpo@democratsabroad.org.