Privacy Policy

Last Updated: November, 2023

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ElectionBuddy, Inc. (“ElectionBuddy”, “we”, “us”, or “our”) offers a simple, secure online voting platform. It facilitates the processes of distributing notifications, recording votes, calculating outcomes, and announcing winners in both virtual and in-person elections, votes, and meetings.

ElectionBuddy's products, features, and offerings are available (a) online via ElectionBuddy.com ("Website"); (b) off platform, including via letters, paper ballots, and printed notices; and (c) via third party webpages and application programming interfaces ("Applications"). We refer to (a), (b), and (c) collectively as the “Services”.

This Privacy Policy describes the privacy practices of ElectionBuddy, and how we handle personal information that we collect through our Services.

If you are a voter using our platform, ElectionBuddy operates as a data processor or service provider with respect to managing and facilitating the voting process on behalf of the vote organizer (i.e., the “Administrator”, defined below) and we process your personal information as instructed by Administrators. ElectionBuddy assists with vote administration, communication, and analysis by providing tools to Administrators; however, we do not control the personal information requested or collected in that context. Any queries about your personal information and how it is processed pursuant to a voting process should be directed to the Administrator. There are instances where we act as a controller (or equivalent under applicable law) with respect to voting information, for example, when we use this information for our own purposes. Such purposes may include aggregating voting data for analysis, conducting statistical research, or improving our Services. For more information, please see the “How We Use Personal Information” section below.

1. 1. PERSONAL INFORMATION WE COLLECT
   Users of our Services fall into one of the following categories:
   2. • “Administrator Users” are individuals using the Services within or on behalf of the administering organization (“Administrator”) (e.g., a university, union, or association), to set up and administer voting processes and includes “Developers” who utilize the ElectionBuddy application programming interface (API) and/or webhooks to create, manage, or integrate voting processes.
      • “Voters” are individuals who engage with the Services to receive information about votes and to participate in voting processes. Voters are invited to use the Services by Administrators.
      • “Prospective Customers” are individuals who are considering or currently engaged in purchasing Services, and those who are seeking information about the Services.

We refer to Administrator Users, Voters, and Prospective Customers collectively as “Users”. The personal information we collect from you depends on how you interact with us and our Services. We have listed below the categories of information that we may collect from Users and any other parties we interact with.

1. 1. 1. Users
         • Contact information, such as your first and last name, email and mailing addresses, phone number, job title or role, and any other information you choose to provide. If you are a Voter, we would only collect such information as a controller (or equivalent under applicable law) if you were to contact us directly with queries.
         • Account information, such as the username and password you use to access our Services as an Administrator User and the key and password you use to access our Services as a Voter.
         • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
         • Marketing information, such as your preferences for receiving marketing communications and details about your engagement with them.
         • Surveys and Reviews and information, such as name, job role, contact information, reviews and survey responses when you complete any of our surveys or write a review on the Services.
         • Usage information, such as information about how you use the Services and interact with us.
         • Payment information needed to complete your transactions with us, including name, payment card information, and billing information. This information is processed by our payment service provider, Stripe, which may handle your payment information in accordance with its own privacy policy. When you make a payment through the Services, we do not have access to your full payment card information.
         • Technical information. We, our service providers, and our advertising partners may automatically log and combine information about you, your computer or mobile device, and your interactions over time with the Services, online resources, and our communications, such as:
           • • Device data, including your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, and general location information such as city, state, or geographic area.
             • Online activity data, including pages, screens and/or features you viewed, accessed and/or used, how long you spent on a page, screen and/or feature, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page, screen and/or feature, access times, duration of access, and whether you have opened or otherwise engaged with our communications, such as our marketing emails, or clicked links or files within them.

           We use cookies, web beacons (e.g., pixel tags), and local and session storage technologies to collect some of this information. For more information on how we use these technologies, please visit our Cookie Policy.

         • Information from third parties.
           • Social media. We may maintain pages on social media platforms, such as LinkedIn, Twitter, and Facebook. When you visit or interact with our pages on those platforms, you or the platforms may provide us with information through the platform.
           • Other sources. We may obtain personal information from other third parties, such as marketing partners, credit reporting agencies, data providers, and other publicly-available sources.
         • Other information not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
      2. Prospective Customers
         • Request Information/Schedule a Demo: when you request a meeting to speak with any of our sales team about the Services or for a demo, we may collect your name, company, job role, contact details and any pre-appointment notes you provide.
         • Recordings. If you engage with the sales team and consent to recording a meeting, the sales team may collect audio and/or video recordings of you.
      3. Voters
         • Voting information. In the course of providing our Services, we may collect personal information in connection with the votes that Voters cast. This includes, but is not limited to, the choices you make in the voting process and any personal information associated with your vote as directed by the Administrator responsible for the vote. It's important to note that while we may aggregate voting information for our analytical purposes, this aggregation process is designed to ensure that individual votes are not identifiable and are not used for our own purposes. Our commitment is to maintain the confidentiality and anonymity of each voter's choices.
      4. Suppliers/Partners and their representatives
         • Administrative information, such as your name, company, job role, contact information, payment information (if applicable) and the content of your communications with us if you have a supplier or partnership agreement or relationship with us or are a representative of any of our suppliers and partners.
   2. HOW WE USE PERSONAL INFORMATION
   We use personal information for the following purposes or as otherwise described at the time of collection:
   3. • Providing and supporting our Services. We use personal information to operate, maintain, and provide you with our Services, including to enable Users to register, pay for Services, cast votes, and view results. In particular, we will use personal information to perform our contractual obligations under our Terms of Service.
      • Communicating with you about our Services. To perform our contractual obligations, or when it is in our legitimate business interests, we will use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.
      • Improving, monitoring, personalizing, and protecting our services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:
        • Understanding your needs and interests, and personalizing your experience with the Services and our communications.
        • Troubleshooting, testing, and research, and to keep the Services secure.
        • Investigating and protecting against fraudulent, harmful, unauthorized, or illegal activity.
        • Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We use anonymization techniques to remove information that makes the data personally identifiable to you. We may use this deidentified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
        • Surveys and Reviews. It is in our legitimate business interest to conduct surveys and collect feedback from reviews you provide to us. Where we intend to publish your survey responses or reviews with information that identifies you we will ask you for your consent to be able to process this information.
        • Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use personal information for the following marketing and advertising purposes:
          • Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Privacy Rights and Choices below.
          • Interest-based advertising. We may engage third-party advertising companies, such as Google, to display our ads on their online services. We may also share information about our website visitors and prospective customers with these companies to facilitate advertising to them or similar users on other online platforms. For more information, or to understand your choices, please visit our Cookie Policy.

Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time, including by following the opt-out instructions in the “Privacy Rights and Choices” section below.

1. 1. • • Supplier/Partner relationships. Where you are a supplier/partner or a representative of a supplier/partner, it is in our legitimate business interests to use your personal information to contact you and to manage our relationship with you and/or your company. If we have entered into a contract with you/your company, we will use your personal information as required for us to perform our contractual obligations under the relevant contract.
        • Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes where it is in our legitimate business interests to do so, including to:
          • Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
          • Audit our internal processes for compliance with legal and contractual requirements and internal policies.
          • Enforce the terms and conditions that govern the Services.
          • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
          • Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
   2. HOW WE DISCLOSE PERSONAL INFORMATION
   For operational and legal purposes, we may share your personal information with certain entities as outlined below:
   3. • Affiliates. Within our family of companies for purposes consistent with this Privacy Policy.
      • Service providers. Companies and individuals that provide services on our behalf or help us operate the services or our business (such as stylists and other support service providers, hosting, information technology, customer support, email delivery, and website analytics services).
      • Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
      • Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
      • Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, ElectionBuddy.
      • Users or other instructed parties. We may disclose personal information to Administrators and other entities or individuals instructed to act on behalf of Administrators – in particular to facilitate voting processes — as well as any other parties that you give us permission to disclose your personal information to in the course of our relationship with you.
      • Advertising partners. Third party advertising companies, including for the interest-based advertising purposes described above, which may collect information on the Website through cookies and other automated technologies.
   4. PRIVACY RIGHTS AND CHOICES

Opt-out of marketing and vote-related communications.

1. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in any marketing communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You may continue to receive service-related and other non-marketing emails.

Administrators may use our tools to send electronic communications to those on their Eligible Voter Lists. Although these electronic communications are sent through our system, ElectionBuddy does not determine the content or the recipients of these electronic communications. ElectionBuddy provides an "Unsubscribe" link on emails, which allows recipients to "opt out" of electronic communications from the particular Administrator for a particular vote. Voters can also communicate with the Administrator directly or ElectionBuddy to remove themselves from the vote communications.

Online tracking opt-out. You can opt out of third-party cookies as described in our Cookie Policy.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:

1. 1. • Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
      • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
      • Correction of personal information that is inaccurate or out of date
      • Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
      • Withdrawal of consent, where we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
      • Additional rights, such as to object to and request that we restrict our use of personal information, as well as the right to data portability.

To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below.

Right to complain. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel your rights have been breached.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

1. 1. OTHER SITES AND SERVICES
   Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.
   2. SECURITY
   We use reasonable organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.
   3. CHILDREN’S PRIVACY
   We do not knowingly collect personal information from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any personal information through the Services. We encourage parents and legal guardians to monitor their children's internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Services, please contact us, and we will endeavor to delete that information from our databases.
   4. INTERNATIONAL DATA TRANSFERS
   You will provide personal information directly to us in Canada and the United States. We may also transfer personal information to our affiliates and service providers in Canada, the United States, and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws. For example, in relation to European personal information, we rely on a European Union (“EU”) Commission or United Kingdom (“UK”) government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.

1. 1. RETENTION
   Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

1. 1. JOB APPLICANTS
   When you visit the Careers portion of our Website, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resumé. This may also include diversity information that you voluntarily provide and that we process on the basis of your consent. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and to respond to surveys. We may also use this information to provide improved administration of the Services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.
   2. CHANGES TO THIS PRIVACY POLICY
   We reserve the right to modify this Privacy Policy at any time. Where we do so, we will update the date of this Privacy Policy and post it on the website. If we make material changes to this Privacy Policy, we will let you know.
   3. HOW TO CONTACT US

Responsible entity.

1. ElectionBuddy, Inc. is the entity responsible for the processing of personal information under this Privacy Policy (as a controller or equivalent, where provided under applicable law).

Contact us. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at privacy@electionbuddy.com or write to us at:

9622 42 Avenue #210
Edmonton, Alberta, T6E 5Y4, Canada