Progressive Acts - Privacy Policy

Privacy Policy – v2 – 05/03/2019

The responsible for data processing on Progressive Acts shall is CrowdChange ASBL, a charity registered in Belgium under the enterprise number 0720.705.149. In processing personal data on Progressive Acts the General Data Protection Regulation (Reg. 2016/679) applies. By using this website or submitting any forms on this site, you will be asked to agree to this Privacy Policy.

We may update these policies from time to time, and if we make any significant changes to the rules that govern this site or the way we treat your personal information, we will add a prominent notice to the website.

Our commitment

Beyond our basic legal obligations, we are committed to transparency and to make our users understand easily what do they agree on. We wrote this Privacy Policy to let you know how we treat that personal information — like your name, contact information, and issues that are important to you – and to show you all the ways we work hard to keep it safe and private. We encourage you to take the time to read it. As a starting point be reassured that we will never sell your data to third parties or provide it to them except in the cases where this is explicitly mentioned in this Privacy Policy.

We tried to draft our Privacy Policy in a way that is as understandable as possible. If you have questions please feel free to contact us at privacy@progressiveacts.eu.

Why do we collect your information?

Progressive Acts is a crowdfunding and grassroot volunteering platform and citizens engagement and participation is crucial to achieve its core objectives. We do process personal data strictly for the purposes of providing a conduit for donation and volunteering in support of individual progressive candidates running for elections. This means that the information provided through the website is first and foremost provided to the candidates themselves so they can stay in touch with respective donors and volunteers.

In line with our Terms of Service candidates, prospective candidates, electoral committees or associations or legal representatives of Candidates are collectively referred to as ‘Candidates’.

In data protection terms us and the candidates will be Joint Controllers of your data, our reciprocal obligations are set forth in a dedicated standard agreement you can find here.

In addition and only if users consent to it we do also store a limited amount of the information provided: name, surname, email, city of residence, country of residence in order to inform you in the future of the activities of Progressive Acts or in view of Campaigns we do believe you could be interested in. At all times users, you can withdraw their consent and erase the information from Progressive Acts. We strive to make this as simple as possible.

What information do we collect from you?

Information we collect depends on who you are. In particular:

    • If you are a Candidate we do need quite some more information in order to set up your account and allow you to use the platform. You will be asked to set up an account by providing your email first. In addition when setting up your campaign we will be asking more information in order to set up your campaign page (Name, Surname, etc…). The personal information you provide when setting up your page will of course be accessible to the public through the page itself.

      As part of your contractual obligation with Progressive Acts information you provide to set up the page will be stored by Progressive Acts for one year after the expiry of your candidate page. In addition, if you provide your express consent we will be storing your personal data for a total of 10 years to contact you back in view of future campaigns (see below).

      As a candidate you will not only provide Progressive Acts with some key personal data we need for you to set up your page but you will also receive quite a lot of personal information from us concerning your donors and volunteers. In using such information you will be bound by the applicable rules and the joint controllership agreement we ask you to sign upon registering.

    • If you are a Volunteer we you will need to fill a dedicated volunteering form for the candidate you want to support. All the information in the form will be transferred to the Candidate himself so he can contact you back.

      As far as Progressive Acts is concerned, we will be asking you if you consent for us to store a limited part of the information in our database to contact you back and you will be able to confirm whether you want your name to appear on the candidate page as a backer.

  • If you are a Donor well it depends.

    If you are supporting an active candidate then you will be filling a form that includes a section concerning your credit card information. That section will be processed directly by a secure donation gateway (Stripe) through an API (want to know more click here). They are GDPR Compliant and they will be handling the payment process including storing any information concerning your credit card. Progressive Acts does not collect nor store any information concerning your credit card.

    Progressive Acts will provide the Candidate concerned with the personal data contained in the donation form. He will be responsible for their handling under the terms of the joint controllership agreement you find here. Be aware that the Candidate may need to provide the information to the relevant electoral authority for campaign finance purposes.

    As far as Progressive Acts is concerned, we will be asking you if you consent for us to store a limited part of the information in our database to contact you back and you will be able to confirm whether you want your name to appear on the candidate page as a backer.

    If you are supporting a candidate whose candidature is not yet active you will need to fill a dedicated ‘pledging’ form. Like for the volunteering form all the information in the form will be transferred to the Candidate himself so he can contact you back.

    As far as Progressive Acts is concerned, we will be asking you if you consent for us to store a limited part of the information in our database to contact you back. and you will be able to confirm whether you want your name to appear on the candidate page as a backer

In line with our general policy on data minimisation we will ask you in our forms if you consent to a limited part of the information you provide (name, surname, city, email) being stored by us to contact you back in the future. We will not store information linking you to a specific candidate (see below on handling of sensitive data).

We also collect from all visitors:

  • Technical information about your use of the website, browser type and version, and operating system.
  • Your IP Address.
  • Our Cookie Policy describes how we collect information via cookies, pixel tags, and other technologies and how to control your Cookie Settings.

If you are under the age of 18, you will not be able to use the functions of the website, sorry.

What do we do with your information?

Your personal information will be used primarily to perform our basic job of connecting you to a candidate and facilitating the process of providing donations or volunteering including sending you a thank you note for your donation or volunteering.

Then it is up to you. If you consent to it, Progressive Acts will store and further use a minimal part of the information you have provided (name, surname, city, email). Otherwise, unless we have an overriding legal obligation to keep your data your personal information will be deleted or completely anonymised.

If you do provide your consent then we will use your personal data to:

  1. Send you information about our work via any channels you’ve consented to: email, phone/SMS, and/or social media messaging.
  2. Give you opportunities to get involved in future campaigns.
  3. Create targeted marketing campaigns to promote our work and engage the public;

We may use the personal information of all visitors of the site to:

  • Answer your queries.
  • Administer & improve the site and optimize our technology.
  • Analyse how you use the site using tools like Google Analytics and other tools to help us test the performance of content and site functionality, understand traffic patterns, and know if there are problems with the site.

Do we share your information?

Progressive acts does not rent or sell your personal information and we will only share it with the parties described below, as required by law, or with trusted third parties.

  • Candidates: When you donate or express willingness to volunteer for one of the candidates on the platform he or she will receive all information you provide in the relevant form.
    All candidates when using the services of this website undertake to use your personal data exclusively for the purposes for which you they have been provided them and not to disclose your personal information to any further recipient or third party unless this is done in compliance with the General Data Protection Regulation (i.e. disclosing information to an electoral authority in charge of verifying lawfulness of donations). For more information see the joint controllership agreement here.
  • Service providers: We may need to work with a wide range of service providers, notably our database administrators, cloud computing services, help desk services, advertising services, data analysts, application service providers, bulk SMS services, voter phone banking services, and other non-governmental organizations. These providers work under strict data protection agreements. We do not authorize them to use or disclose your personal information except in connection with providing their services.
    In particular our server and database hosting company MrDomain is committed to keeping your data inside the EU and only in countries recognised by the European Union as offering a sufficient degree of protection, apply strict security standards.
  • Payment processors: We work with Stripe to help process credit card transactions and other payment methods when you donate to  Candidates. Stripe will store certain personal information about you. Please refer to their privacy policies to learn more about how they use your personal information.
  • Other marketing: Based on your use of this site, we may use cookies to target you for other campaign promotions on Facebook, Google, or other online services. You can read more in our Cookie Policy and control your Cookie Settings.
  • Affiliated Third Parties: In the future, we may transfer your personal information to a third party as a result of a merger, acquisition, reorganization or similar transaction. We will continue to ensure the confidentiality of any personal information and give you notice before personal information is transferred. If there are material changes in relation to the processing of your personal information, we will give you an opportunity to consent to such changes.
  • Protection of Progressive Acts and others: We will share personal information in compliance with the General Data Protection Regulation in particular to comply with requests from regulatory authorities or in other cases of public interest.

How do we keep your information safe?

All Progressive Acts processing operations take place in the European Union. So your information may be transferred and stored across borders but will remain subject to the General Data Protection Regulation. Also when transferred to third parties (i.e. Service Providers) we will make sure they are GDPR compliant before any data can be shared with them. Candidates will also be asked to comply with the terms of the GDPR when setting up their candidature on the Platform.

We use standard industry practices, such as firewalls, encryption and to safeguard your personally identifiable information against unauthorized access, alteration, disclosure, misuse, or destruction. Our database is hosted in servers that guarantee a high level of security.

All donations, including the transmission of payment details and other personal information, are handled over secure, encrypted connections directly by our payment processing gateway (Stripe). As such operations are not handled by Progressive Acts their Terms and Conditions apply. They are GDPR compliant.

We hold on to your personal information for as long as is necessary for the purpose(s) for which it was collected, unless otherwise required by law.

If you request that we stop sending you updates and other communications or delete your information, we will honor your request and keep the minimum amount of information possible to prevent fraud and to help ensure that you are not contacted again. We have made this process as easy as compiling a very simple form.

How can you update and correct your personal information?

You can review and update your personal information via our contact form. You can also change your personal Cookie Settings at any time. All users also have the right to:

  • Restrict or Erase: You can ask us to limit our use of your information or ask us to delete your personal information from our records if there is no compelling reason for us to hold on to it.
  • Object: You can object, on legitimate grounds, to the processing of your personal information, including direct marketing and profiling.
  • Access or Take your data: You can ask us to confirm whether we are processing your personal information. You can also make a reasonable request for a copy of that information or to have it transferred to another data controller (to the extent possible).
  • Complain: You can complain to your country’s data protection authority.

Please note that where we often rely on your consent to use your personal information, all users have the right to withdraw that consent at any time.

What is the lawful basis for processing your information?

When we process your personal information for the purposes set out in this Privacy Policy, we may rely on one or more of the following legal bases:

  • Consent: We will ask for your consent to use your information to send you details about our campaigns, fundraisers, and action opportunities, for targeted advertising and profiling, and if you ever share sensitive personal information with us.
  • Contractual relationships: When you donate to us, apply for employment, or otherwise enter into a contract with us, we’ll need to process your personal information.
  • Legitimate interest: Essentially in all cases where it is rather obvious how we will be using your data and the data you are providing is not sensitive. For instance whenever you fill in our Contact Form to ask something.
  • Legal obligations: When strictly necessary, we’ll process your personal information due to a binding legal obligation on us
  • Vital interest: Processing your data is necessary to protect your vital interest or that of another natural person.

Processing your Sensitive Personal Data: As on Progressive Acts we deal with political action it may be reasonable to assume that your data is considered as sensitive (Article 9 GDPR). For this reason we will only process your data if:

  • the processing is required or permitted by applicable law. In particular for Candidates running for election the information is public or is manifestly provided in order to make it public (i.e. to set up your candidate page);
  • we have obtained your prior explicit consent, for instance whenever you donate or volunteer. Note that for this reason you do not provide your explicit consent we will not be able to process your request (ie. allow you to donate or volunteer.

While we do not allow anonymous donations we do appreciate that you may not want data concerning the person you donate to or volunteer for to be known in public in the unlikely case that we suffer for a data breach.

For this reason, Progressive Acts does not store or retain information linking you to a specific candidate. In case you give your consent for us to store your information we will only keep a record of your name, surname, city and email address while all information linking you to a specific candidate (volunteering or donation) will not be retained.

How can I unsubscribe?

You can ask us to limit our use of your information or ask us to delete your personal information from our records if there is no compelling reason for us to hold on to it. To do so just write to privacy@progressiveacts.eu.

Retention period?

We do retain your personal data if you have given your expressed consent for a maximum period of 10 years. You can always ask us to delete the information earlier.

Candidates can only retain your data in line with the applicable law or the joint controllership agreement they agree to once setting up their page.

How can I get more information?

If you have any questions about this Privacy Policy, your personal information, or data protection on this site, you can contact us at privacy@progressiveacts.eu.