Privacy Policy

This policy is effective April 18, 2023

Privacy Policy

1. Our Service

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.

We invite you to read this Privacy Policy (“Privacy Policy”), which explains our privacy practices and how we handle your personal information collected through CivicBell, as well as through social media, our marketing activities, and other activities described in this Privacy Policy. This Privacy Policy also explains how we use and share such information and the choices you have.

This Privacy Policy governs your rights and responsibilities related to CivicBell’s services including all of CivicBell’s websites, domains, apps, products, services, features and marketing campaigns (collectively, the “Services”).

Unless otherwise indicated, this Privacy Policy applies to all of our Services in all geographies in which CivicBell offers its Services. Certain portions of this Policy apply only to Services offered in particular geographies; please see Section 11 for additional information. Capitalized words used but not defined have the meanings described in the Resident Terms of Service.

2. What information is collected?

We may collect personal information from you, through technology that automatically collects information from your browser or device, and from third party sources. See below for examples. Note that not all CivicBell account types and features are available in all locations, so some of the examples below may not apply where you live. We may also collect personal information that is not specifically listed below, which we use consistent with this Privacy Policy or as otherwise described at the time of collection.

2.1. From you

Your contact details: When you sign up for CivicBell, you may provide your name, address, phone number, profile photo, email address, location, date of birth, gender, demographic information (race, ethnicity, highest educational degree, political affiliation, household income), and similar information. If you contact support, you may provide us with your contact information and a description of the issue so we can respond.
Identity Verification: If you want to engage on the Services as a Resident (as opposed to a Visitor) you will verify your identity with CivicBell, by providing our third-party identification service (currently, https://id.me/) with identity verification information such as ID picture, social security number, drivers license number, etc. Such information is not revealed to or stored by CivicBell.
Data from other accounts: If you use a third party, like Facebook, Google, or Apple to log in to CivicBell (or later connect your third party account to your CivicBell account), then you authorize the third party to share your personal information with us, including your name, photo, email address, and any other information you agree to share.
Posts, interests, location, and recommendations: You may share information about your interests, including joining a discussion board, answering surveys, or following posts from a certain geography or topic. You may post on CivicBell, or send a private message. Posts may include, but are not limited to text, photos, or video, and anything else you want to share.
Payment information: If you make a payment either to or through CivicBell, then you are providing our third-party payment processors (for example, Stripe) with your payment card details and other payment information in order to complete the transaction.
Survey data: As a Resident, you may participate in surveys in your geographic area. If you choose to take part in these, you may provide information, feedback, and comments to us in response.
Contests, sweepstakes, and prize drawings data: If you take part in a contest, sweepstakes, or prize drawing, then you may provide information, feedback, and comments in response.
Messages and email data: We collect information about you when you send, receive, or engage with messages, emails or physical mail in connection with our Services, including whether you have opened or acted on those messages.● Geolocation. You may choose to grant the Services permission to access your device’s precise geolocation, which we use to confirm your address and help us operate and personalize our Services.

2.2. From your browser and device

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:

Device data, such as your device’s manufacturer and model, operating system and version, screen resolution, RAM and disk size, CPU usage, unique identifiers (including identifiers used for advertising purposes), crash data (if applicable), what device settings you’ve enabled, carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area. Your device and software settings affect what information your device makes available to us.
Online activity data, such as the date and time you visited, duration of access, the browser or app version you used (and its settings), the URLs you come from and go to, and how you used CivicBell and interacted with our emails and other messages (for example, how you navigated and which links you clicked on).

Some of the data collection described above is facilitated by cookies and similar technologies, as described in more detail in our Cookie Policy.

2.3. From third parties and public sources

We may collect information from third parties (such as service providers and partners) and public sources. For example:

CivicBell Residents may sync their contacts with CivicBell, including their contacts’ email addresses, mailing addresses, and phone numbers.
Vendors provide us with map and residential address information in order to help us launch CivicBell in new geographic areas and update existing geographic areas.
Public sources, such as census data, voter registration information, street addresses, property lot maps, and postal address change information, provide us with information that helps us understand our Residents and improve our Services.
In the event we include ads in the service, advertisers may provide us with information about their users or potential customers to help us personalize advertising and measure the performance of their advertisements.

3. How is my information used?

We use personal information for the following purposes or as otherwise described at the time we collect it:

3.1. Establishing and developing geographic areas

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.

3.2. Setting you up on CivicBell

To get Residents started on CivicBell, we use personal information to:

Confirm Resident accounts by employing several techniques, including checks against third party data and public records, verification codes, or geo-verification. We also use public registries to block registered sex offenders in the United States (and other countries where permitted by law) from signing up for the Services. In some circumstances, we may ask for additional information (such as government-issued identification and business documentation) to confirm Resident accounts.
Populate Resident profiles and personalize CivicBell.
Offer relevant Public Official Pages, which help Residents learn about the officials in their geographic areas.

3.3. Provide and improve the Services

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:

To operate CivicBell, create geographic areas, suggest geographic areas, and improve our products and features.
To help you create, publish, view, share, and respond to Content, including highlighting interesting posts.
To highlight groups, topics or other resources.
To administer and obtain feedback via surveys, initiatives, events, sweepstakes, contests, or other promotional activities.
To provide RSS feeds that contain local news and relevant news from national news outlets that reference your geographic area.
To add events you choose to add directly to your calendar.
To highlight Public Official Pages you may be interested in.
To personalize your experience.
To understand the trends, usage statistics, and demographic data of the Residents and geographic areas we serve.
To respond to your support requests and comments.
To test and evaluate potential new products and features on CivicBell.
To diagnose and resolve problems, analyze trends, and monitor usage and resource needs.
To accept payments, through our third party payment processors.
To facilitate sending urgent alerts.
To communicate with you about the Service, including by sending announcements, updates, security alerts and support messages via email, notifications, and text messages.

3.4. Create and maintain a trusted environment

We may use your information to help create and maintain a trusted environment on CivicBell, including:

To detect and prevent fraud, spam, abuse, security incidents, and other harmful, unauthorized, unethical or illegal activity.
To conduct security investigations, audits and risk assessments.
To comply with our legal obligations.
To confirm or authenticate information or identification.
For the legal and safety reasons described below in Section 4.3.

3.5. Advertising

In the event we include ads on the Service, we may use your information to provide and improve advertisements and other commercial offerings both on and off the Services. Third party advertising partners may also use cookies and similar technologies to collect information about Residents for advertising purposes as described in Section 4.4 below and in our Cookie Policy.

3.6. Research and Development

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.

4. Is my information shared with third parties?

We share personal information as follows:

4.1. Content shared on CivicBell

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.

4.2. Account confirmation

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.

4.3. Legal and safety reasons

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.

4.4. Advertising

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.

The Services may be supported by third party advertising networks in the event we include ads on our Service. With your consent, our advertising partners use cookies and similar technologies to collect information about our Residents and their devices over time across CivicBell and other online services. Where permissible according to applicable law, we may share certain limited personal information, such as hashed emails and advertising identifiers, with our advertising partners that help serve targeted online advertising to those Residents or to similar audiences. Our advertising partners may be able to associate this information with you based on your advertising identifiers or other personal information they have about you. Our advertising partners then use the information they collect to provide our Residents with personalized ads on CivicBell and on different websites and services, and to measure the effectiveness of the ads.

4.5. Service providers

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.

4.6. Social Media

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.

4.7. Business reorganization

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).

4.8. Professional advisors

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.

4.9. Payment processors

Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor.

5. What are my choices?

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.

You can opt out of third-party personalized advertising by adjusting your cookie settings or changing the privacy settings on your mobile device. For more information about third party use of cookies, mobile advertising identifiers, and similar technologies and how to adjust your settings, see our Cookie Policy. Our systems are not currently configured to accept browsers’ “Do Not Track” signals, as no industry-wide standard for handling them has been adopted.

See our jurisdiction-specific disclosures in Section 11 below for more information about legal rights you have if you live in a listed jurisdiction.

6. How long is my information kept?

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.

7. How is my information protected?

7.1. Account security

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.

7.2. Other services and websites

When using CivicBell, you may come across links to websites and services operated by third parties that are not owned or controlled by CivicBell. This Privacy Policy does not apply to information collected on any third-party site or application that may link to or be accessible from the Services. These third parties have their own privacy policies, which will apply to any personal information they collect. We do not accept any responsibility or liability for such external sites’ privacy and security practices.

8. Children

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 legal@civicbell.com, and if we learn that we have, we will delete their personal information.

9. Amendments to this Privacy Policy

We may make changes to this Privacy Policy from time to time, so please review it periodically. If we materially change our Privacy Policy, we will take steps to notify you in advance of the change as required by applicable law, for example by emailing you or by posting a notice in your feed. If you object to any changes, you may close your account. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use, and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

10. Contact us

11. Jurisdiction-specific disclosures

11.1. California

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.

11.1.1. Personal information we collect, use, and disclose

The chart below summarizes the personal information we collect by reference to the categories of personal information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. More information regarding the sources from which we collect personal information can be found in Section 2 above titled “What information is collected?”; business and commercial purposes for which we collect your personal information can be found in Section 3 above titled “How is my information used?”; categories of recipients with whom personal information is shared or sold can be found in Section 4 above titled “Is my information shared with third parties?”

Statutory category of personal information (PI) (Cal. Civ. Code § 1798.140)	PI we collect in this category (See Personal information we collect above for description)	Source of PI	Business/ commercial purpose for collection	Categories of third parties to whom we “disclose” PI for a business purpose
Identifiers (other than online identifiers)	Contact details, Network details; Data from other accounts; Posts; interests; location;, and recommendations; Information from third parties and public sources	You; Third parties and public sources	Establishing and developing geographic areas, Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment; Advertising; Research and development; Payment processors	Public; Verification partners, Legal and safety-related third parties; Advertisingpartners, Third party partners Business transferees,;Professionaladvisors; Payment processors
California Customer Records (as defined in California Civil Code section 1798.80)	Contact details; Network details; Data from other accounts; Posts, interests, location, and recommendations; Paymentinformation; Business information; Booking information; Information from third parties and public sources	You; Third parties and public sources	Establishing and developing geographic areas; Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment;Advertising; Research and development; Payment processors	Public; Verification partners; Legal and safety-related third parties; Advertising partners; Third party partners; Business transferees; Professional advisors; Payment processors
Commercial Information	Contact details; Network details; Posts, interests, location, and recommendations; Payment information; Survey data; Contests, sweepstakes, and prize drawings data; Messages and email data; Business information; Booking information; Online activity data; Information from third parties and public sources	You; Your browser and device; Third parties and public sources	Establishing and developing geographic areas; Setting you up on CivicBell Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment; Advertising; Research and development; Payment processors	Public; Verification partners; Legal and safety-related third parties; Advertising partners; Third party partners; Business transferees; Professional advisors
Financial Information	Payment information	You	Provide and improve the Services; Create and maintain a trusted environment;Research and development; Payment processors	Legal and safety-related third parties; Third party partners; Business transferees; Professional advisors
Online Identifiers	Messages and email data;Contact lists; Geolocation; Device data; Online activity data; Information from third parties and public sources	You; Your browser and device; Third parties and public sources	Establishing and developing geographic areas; Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment;Advertising; Research and development; Payment processors	Verification partners;Legal and safety-related third parties; Advertising partners; Third party partners; Business transferees; Professional advisors
Internet or Network Information	Messages and email data;Device data; Online activity data	You; Your browser and device; Third parties and public sources	Establishing and developing geographic areas; Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment;Advertising; Research and development; Payment processors	Verification partners;Legal and safety-related third parties; Advertising partners; Third party partners; Business transferees; Professional advisors
Geolocation Data	Geolocation; Device data	You; Your browser and device	Establishing and developing geographic areas; Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment;Advertising; Research and development; Payment processors	Legal and safety-related third parties; Advertising partners; CivicBell corporate family; Business transferees; Professional advisors
Inferences	May be derived from your:Contact details; Network details; Posts, interests, location, and recommendations; Survey data; Contests, sweepstakes, and prize drawings data; Messages and email data; Geolocation; Device data; Online activity data; Information from third parties and public sources	N/A	Establishing and developing geographic areas; Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment;Advertising; Research and development	Legal and safety-related third parties; Advertising partners; Third party partners; Business transferees; Professional advisors
Professional or Employment Information	Business information;Information from third parties and public sources	You; Third party sources	Establishing and developing geographic areas; Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment;Advertising; Research and development	Public; Verification partners; Legal and safety-related third parties; Advertising partners; Third party partners; Business transferees; Professional advisors
Sensory Information	Photos and videos	You	Establishing and developing geographic areas; Setting you up on CivicBell; Provide and improve the Services; Create and maintain a trusted environment;Advertising; Research and development	Public; Legal and safety-related third parties; Third party partners; Business transferees; Professional advisors

11.1.2. What are my rights?

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.

11.1.2.1. Access Categories of Information

You may request the following information about how we have collected and used your personal information during the past 12 months:

the categories of personal information we have collected about you;
the categories of sources from which we collected the personal information;
the business or commercial purpose for collecting or selling the personal information;
the categories of third parties with whom we share the personal information;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose.
the categories of personal information that we sold or disclosed for a business purpose; and

You may make this request by submitting a request via email legal@civicbell.com and a signed request letter to Civic Bell LLC, 265 Cambridge Ave, Suite 60908, Palo Alto, CA 94306.

11.1.2.2. Access

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 legal@civicbell.com and a signed request letter to Civic Bell LLC, 265 Cambridge Ave, Suite 60908, Palo Alto, CA 94306.

11.1.2.3. Deletion

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 legal@civicbell.com.

11.1.2.4. Opt-out of sales

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.

11.1.2.5. Nondiscrimination

You are entitled to exercise your rights described above free from discrimination as prohibited by the CCPA.

11.1.3. Requests by authorized agents

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.

11.1.4. Verifying requests for information, access, and deletion

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.

11.1.5. Shine the light

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 legal@civicbell.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.

11.2. Australia, Canada, UK, and Europe

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.

11.2.1. On what legal basis do you collect my information?

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.

11.2.1.1. Performing the Resident Terms of Service

CivicBell processes your information as is necessary to perform our contract with you, the Resident Terms of Service. For example:

we use your information in order to create your account and set you up as an Visitor on CivicBell;
we transfer your information outside of the EU to the U.S., such as to CivicBell LLC, in order to provide the Services.

11.2.1.2. Your Consent

CivicBell processes certain information based on your consent, which you may revoke at any time. For example:

we and our partners use cookies and similar technologies, as described in more detail in our Cookie Policy, based on your consent;
we rely on your consent to tailor ads based on off-CivicBell actions and information, including based your activity on other websites and partner data, such as inferred interests;
we will send you marketing communications where you have consented to receiving such communications in accordance with applicable law;

11.2.1.3. Legal Obligation

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:

we may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g. a subpoena, search warrant, court order, or other binding request from government or law enforcement); and
we may retain and process your information where it is necessary for compliance with applicable tax laws.

11.2.1.4. Vital Interests

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 need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person, including you, other Residents, Observers, our staff, or the public;
we may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat;
we may share your personal information with disaster relief agencies, first responders and other individuals to facilitate disaster or emergency response efforts.

11.2.1.5. Legitimate Interests

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:

Keeping the Services safe and secure: We use your information because it is necessary to pursue our and our Residents’ legitimate interests in ensuring CivicBell is secure, such as implementing and enhancing security measures and protections, protecting against fraud, spam and abuse, and enforcing our Resident Terms of Service.
Providing, improving, and developing the Services: We use your information to provide the Services, including any personalized services, and to understand and improve our business and our Resident relationships. We do so as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Residents on a sustained basis.
Providing ads, and measurement and analytics services: We use your information to provide personalized ads both on and off CivicBell and to measure and analyze the success of those ads in order to provide accurate and reliable reporting to our advertisers. We do so as necessary to pursue our legitimate interests of marketing and monetizing our Services.
Sending marketing communications: We rely on our legitimate interests in marketing and promoting our Services to use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.
Sharing information for legal and safety reasons: Where required for legal and safety reasons, we may disclose information to law enforcement and related agencies and authorities in furtherance of the legitimate interests described further below.

As detailed in the Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.

11.2.2. What are my rights?

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.

11.2.3. Access

Email us at legal@civicbell.com 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.

11.2.4. Rectify, restrict, delete.

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 support@civicbell.com and we will rectify, restrict, or delete your information if requested and if required to do so by applicable law.

11.2.5. Object

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 support@civicbell.com.

11.2.6. Revoke consent

Where consent is required for processing under applicable law, you may have the right to withdraw your consent to the processing of your information at any time. If you withdraw your consent to the use of your information for the purposes set out in this Privacy Policy, you may not have access to all (or any) of our Services and we might not be able to provide you all (or any) of the Services under this Privacy Policy and our Resident Terms of Service. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so, or if your withdrawal of consent was limited to certain processing activities.

11.2.7. Complain

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.

11.3. Where is my information stored?

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.