Privacy Policy

June 24, 2019

OUR COMMITMENT TO PRIVACY

Prytany LLC knows that you care about how your personal information is used and shared, and we take your privacy seriously. Accordingly, we have adopted a written information security program. We understand that you may have questions or concerns regarding how your personal information that you provide to Prytany will be used and secured by Prytany. To make this Privacy Policy and our written information security program easy to find, we make them available on the home page of the Prytany website at prytany.com (the "website") and, for our Privacy Policy, also through our mobile applications. You may also email us at prytany.com with any privacy-related questions you have.

Capitalized terms used in this Privacy Policy but not otherwise defined in this Privacy Policy have the meanings given to them in our User Agreement. Our User Agreement is available on our website.

APPLICABILITY OF PRIVACY POLICY

This Privacy Policy applies to all information we collect through our web and mobile applications from Prytany users, including you. When you are no longer a Prytany user, we will continue to share your information as described in this policy. This policy only applies to your use of Prytany and does not apply to the practices or service of any payment processing service used by you through Prytany’s web and mobile applications.

Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user. Prytany will own such aggregated and anonymized information.

THE INFORMATION WE COLLECT

When you visit the Prytany website or use one of our mobile applications, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed in our website. We also may collect certain geo-location information. If you do not agree to our collection of this information, you may not be able to use Prytany.

If you register as a Prytany Constituent, a Registered Campaign, a Registered National Party Committee or a Political Action Committee (PAC), we collect the following information from you:

Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information, and your user name and password.
Identification Information - your full name, mailing address, email address, and date of birth. If you desire to make a political contribution or pledge using the Prytany Platform, we also will require you to give us your occupation and the name of your employer. If we need to verify your identification, we also may require you to scan and send to us, using the ID scanning application provided on the Prytany website, a picture of your driver’s license or other government-issued identification card, which may include your US passport, and in certain cases we also may require you to provide us with your Social Security Number. Prytany will not store the scanned images of your identification card although it will retain the unique identifying barcode or other identifier for future user access verification purposes and to avoid multiple accounts for the same individual. Prytany will comply with the requirements of the US Social Security Administration with respect to the secure storage of your Social Security Number. For a Registered Campaign, we collect such identification information about the authorized officer associated with such campaign (usually its Treasurer) and the Federal Election Commission Identification Number assigned to such campaign. For a Registered National Party Committee, we collect such identification information about the chairperson or treasurer of such national party committee and the Federal Election Commission Identification Number assigned to such committee. For a PAC, we collect such identification information about the authorized officer associated with such committee (usually its Treasurer) and the Federal Election Commission Identification Number assigned to such PAC.
Device Information - information about you: (a) from your mobile device such as your device type, machine or mobile device identification number, media access control address, geo-location, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes.
Social Web Information - including but not limited to your email account information. Social and e-mail contact information helps you send messages to other members of your Groups (as well as helping us improve our service and fight fraud). You may manage certain contact preferences and notifications in your account settings.
Other information - we may collect additional information from you not specifically described here that we request and that you permit us to collect.

Before permitting you to use or to continue using Prytany, we may require additional information from you that we can use to verify your identity or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar service.

When you are using Prytany, we collect information about your Prytany Account activity, including your contribution, pledge and messaging history and your interests in political and social causes. We also may collect information about your mobile device, computer or other access device for fraud prevention and other similar purposes.

When you make a contribution using Prytany, your designated preferred funding source (either your bank account and routing number or your debit and credit card) will be shared with Prytany’s payment processing service provider. Prytany, however, will not have full visibility of such information and will not store such financial information. We will collect information about your contribution and pledge amounts and the recipients of your contributions and pledges and will assign you a rating based on your contribution and pledge history.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contacts with us.

INFORMATION FROM CHILDREN

We do not knowingly solicit or collect information from any individuals under the age of 13. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, such information will be deleted from our system.

HOW WE USE COOKIES

When you visit our website, use our mobile application or the Prytany Platform, we may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a Prytany user; customize Prytany for your use, customize other content and contribution opportunities for you; measure the effectiveness of our profiling of Prytany users; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across our sites and the Prytany Platform.

Certain aspects and features of the Prytany Platform and our website are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of our website and the Prytany Platform may be limited or not possible.

Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not track users unless they enable the “remember me” feature on the Prytany signup page, in which case we store their email/username using browser cookies. If you set DNT, then you will be unable to utilize the “remember me” feature for future log-ins to your Prytany Account.

HOW WE PROTECT AND STORE PERSONAL INFORMATION

We store and process your personal information using third party servers located in data centers in the United States. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. We comply with the requirements of the US Social Security Administration with respect to the secure storage of your Social Security Number.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information will not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Prytany password with anyone.

If Prytany learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Prytany Platform, you agree that Prytany may communicate with you electronically. Prytany may post a notice on its website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. You consent to receiving notices by email. You agree to provide Prytany up-to-date contact information, including email address. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at privacy@Prytany.com.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

We may use your personal information to:

provide the service and support you request;
process your contributions and pledges, monitor and send notices to you about your contributions and pledges, and assign you a rating based on your activity on the Prytany Platform;
resolve disputes, collect fees, and troubleshoot problems;
prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement;
create an account connection between your Prytany Account and our third-party payment processing service provider;
customize, personalize, measure, and improve our service and the content and layout of our website;
send you updates about political news and political candidates, campaigns and other organizations;
compare information for accuracy and verify it with third parties;
perform other duties as required by law; and
perform analytics using aggregated and anonymized information based on information provided by you.

HOW WE SHARE PERSONAL INFORMATION WITHIN THE PRYTANY PLATFORM

To process contributions and pledges made using the Prytany Platform, we need to share some of your personal information with the payment processing service linked to the Prytany Platform and the Registered Campaign, Registered National Party Committee or PAC to which you are contributing or pledging. Your contact information, date of sign-up, date of birth, occupation, employer, the number of contributions and pledges you have made and other rating and verification metrics may be provided to the Registered Campaigns, Registered National Party Committees, PACs and, depending on your privacy settings, other Prytany users in a Group that you have created or joined when you use the Group feature of the Prytany Platform.

We work with Registered Campaigns, Registered National Party Committees and PACs to enable them to accept contributions and pledges from you using Prytany. We confirm to that Registered Campaign, Registered National Party Committee or PAC that you are a Prytany Constituent and that the Registered Campaign, Registered National Party Committee or PAC should accept your contribution or pledge via the Prytany Platform.

We do not access or store your credit card number or bank account number and therefore cannot disclose it to anyone. That information will be provided to our third-party payment processing service enabled via Prytany and it will be safeguarded in accordance with their privacy policies.

HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

Prytany does not share your personal information with third parties for their promotional or marketing purposes.

We may share your personal information with:

Companies that Prytany LLC plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this privacy policy, as updated from time-to-time, with respect to your personal information. If your personal information could be used by us or our successor contrary to this policy, you will receive prior notice from us or our successor and the opportunity to communicate preferences you may have, if applicable.
Law enforcement, government officials, or other third parties if Prytany is requested to do so by a subpoena, court order or similar legal procedure, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Prytany User Agreement, or as otherwise required by law.
Third party service providers who assist us in making the Prytany Platform available to you or who provide identification verification, fraud detection or similar services on our behalf or on behalf of the payment processing service enabled by Prytany or any Registered Campaign, Registered National Party Committee or PAC.
The Registered Campaign, Registered National Party Committee or PAC receiving your contribution or pledge.
Depending on the privacy setting of your Prytany Account and of any Prytany Group that you may create or join, your Prytany Group members and the Prytany Group members of the Registered Campaign, Registered National Party Committee or PAC receiving your contribution or pledge.
Service providers under contract who help with parts of our business operations (for example, identity verification, fraud prevention, payment processing, website and database hosting and administration, business support service, internet service and information technology service). Our contracts dictate that these service providers only use your information in connection with the service they perform for us and not for their own benefit.
Your bank or credit card issuer with your consent and at your direction to do so, including if you authorize an account connection with your bank or credit card issuer.

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You can review and update your personal information in your Prytany Account settings at any time by logging in to your Prytany Account.

LINKS TO OTHER SITES

The Prytany website or mobile application may contain links to other third-party websites. Prytany does not control the information collection of third-party websites that can be reached through links from the website. We encourage our users to be aware when they are leaving the Prytany website and to read the privacy statements of any third-party website that collects personally identifiable information.

CHANGES TO OUR PRIVACY POLICY

Prytany is always improving. As the Prytany Platform evolves we may occasionally update our Privacy Policy. If we modify this Privacy Policy, we will post a link to the revised Privacy Policy on the homepage of our website, and we will also revise the date first stated above. If we make material changes in the way we use personal information, we will notify you by posting an announcement on our mobile application or on the homepage of our website or by sending you an e-mail. It is your responsibility to periodically review this Privacy Policy; users are bound by any changes to the Privacy Policy by using the Prytany Platform after such changes have been first posted.

HOW TO CONTACT US

If you have questions or concerns regarding this Privacy Policy, or any feedback pertaining to your privacy and the Prytany Platform that you would like us to consider, please email us atcontact@prytany.com or write to us at c/o Prytany LLC, 786 Stephanie Circle, Great Falls, VA 22066.

Consumer Privacy Notice

Prytany is a political contribution and messaging platform provided by Prytany LLC ("Prytany") and as such is considered to be a social platform.

Facts

What does Prytany do with your personal information?

Why?

Social platform companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and, in certain cases, share depend on the way you use the Prytany Platform. This information can include:

Your full name, mailing address, email address and date of birth
Your occupation and employer
A scanned picture of your driver’s license or other government-issued ID, including your US passport
Your Social Security Number
Your contribution history, including pending periodic contributions and pledges made using the Prytany Platform

When you are no longer a Prytany user, we continue to share your information as described in this notice.

How?

All social media platform companies need to share users’ personal information to run their everyday business. In the section below, we list the reasons social media platform companies can share their users’ personal information; the reasons Prytany chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does Prytany share?	Can you limit this sharing?
For our everyday business purposes— such as to process your contributions and pledges, to maintain your Prytany Account, to respond to court orders and legal investigations, and to report to Registered Campaigns, Registered National Party Committees and PACs	Yes	No
For our marketing purposes— to offer our platform to you	Yes	No
For joint marketing with other companies	No	We don't joint market
For our affiliates’ everyday business purposes— information about your contributions and experiences	No	We don't share with any affiliate
For our affiliates’ everyday business purposes— information about your creditworthiness	No	We don't share with any affiliate
For our affiliates to market to you	No	We don’t share with any affiliate
For nonaffiliates to market to you	No	We don’t permit our contract partners to market to you

Who we are

Who is providing this Privacy Policy?

This privacy notice is provided by Prytany LLC in connection with its provision of Prytany, and is applicable to your personal activity on the Prytany Platform.

What we do

How does Prytany protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal and applicable state law. These measures include computer safeguards and secured files and buildings.

How does Prytany collect my personal information?

We collect your personal information, for example, when you

create a Prytany Account or provide account information
give us your contact information
use the Prytany Platform to make a political contribution or pledge
use the ID card scanning application provided on the Prytany website

Why can’t I limit all sharing?

Federal law gives you the right to limit only

sharing for affiliates’ everyday business purposes — information about your creditworthiness

We do not share your personal information with any affiliate

affiliates from using your information to market to you

We do not share your personal information with any affiliate

sharing for nonaffiliates to market to you

We do not permit our contract partners to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law.

Definitions

Affiliates: Companies related by common ownership or control.
Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.; Nonaffiliates with which we share personal information include service providers that perform service or functions on our behalf.
Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial products or service to you.; We have no joint marketing partners.

Other important information

We do not transfer personal information to other countries.

California: If your Prytany Account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.

Vermont: If your Prytany Account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows or you provide authorization.