This policy is effective April 18, 2023
Welcome to CivicBell, owned and operated by CivicBell LLC (“CivicBell”, “we”, “us” and “our”). CivicBell is a civic engagement platform designed to improve the connection and communication between Americans and their government officials.
With your permission, where it is required by applicable laws, we, our service providers and partners collect technical information when you visit or use CivicBell, engage with our partners, or interact with our or our partners’ marketing communications, including:
We may collect information from third parties (such as service providers and partners) and public sources. For example:
We use personal information for the following purposes or as otherwise described at the time we collect it:
We use personal information to identify and invite potential new Residents to CivicBell, and to set up new CivicBell geographic areas. For example, you can ask us to send invitations to potential new Residents and reminders on your behalf, send direct mail invitations, invite your friends, or notify you when we start offering the Services to your geographic area.
To get Residents started on CivicBell, we use personal information to:
We use both manual and automated systems to analyze and use your Content (as defined in the Resident Terms of Service) and other information, including:
We may use your information to help create and maintain a trusted environment on CivicBell, including:
We may use your personal information for research and development purposes. As part of these activities, we may create aggregated, de-identified and/or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
We share personal information as follows:
CivicBell is a platform for users to engage and share information with each other. To that end, the Content you post on CivicBell, such as discussion board comments, messages, and your profile information, may be visible to other Residents, Public Officials, or the public, including Visitors (as defined in the Resident Terms of Service) and search engines. Please be sure to read the options you have under the “What are My Choices” section below. If this information is cached by third party search engines or other third parties, please note we do not control the practices of these third parties, and they may use caches containing outdated information. Please consult these third parties’ privacy policies.
We may share your personal information with our verification partners, such as id.me and data providers to confirm your account.
You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to us or our service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud.
We may retain, preserve, or share your Content and personal information with law enforcement, government authorities, and private parties if we have a good-faith belief that it is reasonably necessary to: (a) respond, based on applicable law, to a legal request (e.g. a subpoena, a search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other unauthorized, illegal or unethical activity, security, or technical issues; (c) protect our or others’ rights, property, or safety; (d) enforce our Resident Terms of Service or any other agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including you and Residents of the general public. For example, we may share your personal information with disaster relief agencies, first responders, and other individuals to facilitate disaster or emergency response efforts. Pursuant to public records requirements, we will not delete anything any Public Official posts on this platform — even when they delete a post it will still be retained by us and if there is a public records access request, we will also release deleted posts.
In the event we include ads on our Service, if you view, click on, or reply to an advertisement or other offer on the Services, we may share your reply and limited Resident profile information with the advertiser, and we may log your interaction as part of tracking the overall effectiveness of the advertisement. We may also pre-populate replies to ads you click on with your contact details, but those details are not shared with the advertiser without your consent.
We may also share your personal information with service providers and/or data processors to help us operate, provide, improve, understand, customize, support, and market our Services. These service providers and data processors are contractually required to use it only to provide their service to us, and are contractually prohibited from using it for their own purposes. They provide a variety of services, including payment processing, information technology, cybersecurity, fraud prevention, hosting, customer relationship management and support, communications delivery, marketing, advertising, and website and mobile application analytics.
Our Services include certain social media features, including social media share button. If you choose to share a post using the social media share button, information about that Content will be shared with the relevant social media platform.
We may need to share your personal information with the relevant participants in transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, restructuring, reorganization, or sale or other disposition of some or all of the assets of, or equity interests in, CivicBell or our affiliates (including, in connection with a bankruptcy or similar proceedings).
We may share personal information with our professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor.
You can choose the degree to which your personal information, such as whether your full name is displayed in your personal profile and alongside your posts by using your account settings. You can modify these account settings at any time.
See our jurisdiction-specific disclosures in Section 11 below for more information about legal rights you have if you live in a listed jurisdiction.
We retain your information in our server logs, our databases, and our records for as long as necessary to provide the Services. We may need to retain some of your information for a longer period, such as in order to comply with our legal or regulatory obligations, to resolve disputes or defend against legal claims, or to enforce our Resident Terms of Service.
CivicBell uses physical, technical and organizational measures intended to keep your data secure, including using https on our web pages to reduce the risk of unauthorized interception of your communications during your visits to the website. We use encryption to keep your data private while in transit. We restrict access to personal information to CivicBell employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. However, the internet is not a fully secure environment and we cannot guarantee that your personal information won’t be intercepted or improperly accessed. Please ensure that you keep your password safe and do not share it with anyone.
Children are not allowed to use the Services if they are under 13 years old or not old enough for CivicBell to process their personal information without parental or age-specific consent where they live. If you believe we might have collected personal information from a child in one of these categories, please contact us at firstname.lastname@example.org, and if we learn that we have, we will delete their personal information.
Contact us at Civic Bell LLC, 265 Cambridge Ave, Suite 60908, Palo Alto, CA 94306; Email: email@example.com
If you are a California resident, this section applies to you. This section describes how we collect, use, and share your personal information in our capacity as a “business” under the California Consumer Privacy Act of 2018 (“CCPA”), and the rights that you have with respect to your personal information. For purposes of this section, “personal information” has the meaning given in the CCPA, but does not include information excluded from the CCPA’s scope.
The following rights are not absolute and are subject to exceptions, and we may be required or permitted by law to decline your request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
You may request the following information about how we have collected and used your personal information during the past 12 months:
You may make this request by submitting a request via email firstname.lastname@example.org and a signed request letter to Civic Bell LLC, 265 Cambridge Ave, Suite 60908, Palo Alto, CA 94306.
You can see much of your personal information by logging into your CivicBell account.
You may request a copy of the personal information we have collected about you during the past 12 months by submitting a request via email to email@example.com and a signed request letter to Civic Bell LLC, 265 Cambridge Ave, Suite 60908, Palo Alto, CA 94306.
You can remove most content you have posted to CivicBell by logging into your CivicBell account.
You may request that we delete personal information we have collected from you by submitting a request via email to firstname.lastname@example.org.
We use services that help deliver interest-based ads to you, which enable us to provide the Services and relevant offers to you.
Our use of these services may be classified under the CCPA as a “sale” of your personal information to the advertising partners that provide the services because they collect information from our users (i.e., the device data and online activity data described in Section 2.2) to help them serve ads more likely to interest you.
You can request to opt-out of this “sale” of your personal information by clicking on the “Do Not Sell My Personal Information” link, where you will find instructions on opting out of the use of your information for interest-based advertising.
You are entitled to exercise your rights described above free from discrimination as prohibited by the CCPA.
Your authorized agent may make a request for information, access, and deletion on your behalf upon our verification of the agent’s identity and our receipt of a copy of valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. Authorized agents are required by California law to implement and maintain reasonable security procedures and practices to protect their clients’ information.
We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency.
If you are a Resident, you can verify your identity by submitting your request while logged into your CivicBell account.
If you are a Visitor or a Resident who is unable to log in to your account, we may verify your identity by requiring you to provide government identification, give a declaration as to your identity under penalty of perjury, reply to a text message sent to the phone number we have in our records, and/or provide additional information.
Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to CivicBell LLC, 265 Cambridge Ave, Suite 60908, Palo Alto, CA 94306, with copy to email@example.com. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, email, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
If you live in the UK or Europe, this section applies to you. If you live in Australia or Canada, you may have some of the following rights under applicable law. Note: we do not provide the Services to users outside the United States as Residents, only as Visitors.
To the extent required by applicable law, we will collect your personal information with your consent where required and in accordance with our legitimate need to provide you our Services.
Under EU law, CivicBell is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.
CivicBell processes your information as is necessary to perform our contract with you, the Resident Terms of Service. For example:
CivicBell processes certain information based on your consent, which you may revoke at any time. For example:
CivicBell may process your information in order to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:
CivicBell might process your information in certain circumstances when it is necessary to protect your vital interests, or those of others. For example:
We may process your information where it is necessary for the purposes of CivicBell’s or a third party’s legitimate interests, such as those of Visitors, Residents or partners. In particular, we process your information in furtherance of the following legitimate interests:
You benefit from a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below.
In certain cases, such as for access to, rectification or deletion of your information, please be sure to read the options you have under the “What are My Choices” section above.
Email us at firstname.lastname@example.org to request a copy of your CivicBell information. If requested and required to do so by applicable law, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties as you request.
You can access, rectify, and delete your CivicBell information by logging into your CivicBell account. If you cannot do this or you do not have a CivicBell account, please email us at email@example.com and we will rectify, restrict, or delete your information if requested and if required to do so by applicable law.
If we process your information based on our legitimate interests explained above, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing (including if we are permitted to continue processing under applicable law) or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object by using the unsubscribe link in such communications, changing your settings or by emailing us at firstname.lastname@example.org.
EEA residents have the right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
The Services are intended for use in the United States and as such we transfer your personal information to secure servers in primarily the States of California and Oregon, with secondary server locations throughout the U.S.