This Privacy Policy describes how America First LLC, a Nevada limited liability company, together with its affiliates (collectively, the "Company," "we," "us," or "our"), collects, uses, stores, processes, and discloses information in connection with the websites, web applications, APIs, platforms, and related products and services offered under the brand ConstituencyData and its product Civitas (collectively, the "Service").
By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy and that your use of the Service is governed by it and by our Terms of Use.
1. Information We Collect
We collect information about you and your use of the Service from a variety of sources, including directly from you, automatically from your device and browser, and from third parties. The categories of information we collect include, without limitation, the following:
1.1 Information you provide to us
- Account and registration data: your name, email address, mailing address, telephone number, organization, title, role, professional affiliations, geographic region, race or office you are associated with (if any), and any other information you submit during sign-up or onboarding.
- Authentication credentials: passwords, passphrases, one-time codes, multi-factor authentication tokens, and similar credentials you use to access the Service. Passwords are stored in hashed or otherwise cryptographically protected form.
- Billing and payment information: billing name and address, payment-method details, transaction history, tax-identification information, and related financial information. We typically rely on third-party payment processors to process payments and may not directly store full card numbers.
- Content you submit: queries, prompts, instructions, documents, datasets, files, lists, spreadsheets, messages, drafts, campaign assets, audio, images, video, feedback, and any other content you upload to or generate through the Service (collectively, "Submitted Content").
- Communications with us: emails, chat messages, voicemails, support tickets, survey responses, and any other communications you direct to us.
1.2 Information collected automatically
When you access or use the Service, we and our service providers automatically collect information about your device, your network, and your interactions with the Service, including without limitation:
- Device and browser data: device identifiers, operating system, hardware model, browser type and version, screen resolution, language settings, time-zone offset, device sensors where available, and similar technical attributes.
- Network and location data: IP address, approximate geolocation inferred from IP, internet service provider, connection type, and referring URL.
- Usage data: pages viewed, features used, buttons clicked, queries run, charts built, exports generated, session duration, navigation paths, crash and diagnostic logs, and similar telemetry.
- Cookies and similar technologies: we and our service providers use cookies, pixels, web beacons, local storage, session storage, and similar technologies to authenticate users, remember preferences, analyze usage, measure effectiveness, and secure the Service. See Section 5 below.
1.3 Information from third parties
We may receive information about you from third parties, including without limitation:
- authentication, identity-verification, and single-sign-on providers;
- payment processors and fraud-prevention vendors;
- analytics, attribution, and advertising partners;
- data suppliers, licensors, and campaign-finance and voter-data sources;
- publicly available records, government filings, and public registries;
- campaigns, organizations, or other account administrators that grant you access to the Service on their behalf.
2. How We Use Information
We use the information we collect for a broad range of purposes, in each case as permitted by applicable law and as we deem necessary or appropriate, including without limitation to:
- provide, operate, maintain, secure, personalize, and improve the Service;
- authenticate users, prevent fraud, enforce our Terms of Use, and comply with law;
- process payments, manage subscriptions, and send transactional communications;
- communicate with you about the Service, updates, promotions, research, and events;
- develop, train, evaluate, and tune models, features, datasets, and infrastructure, including artificial-intelligence models, where permitted by law and where such information does not identify a specific individual in violation of applicable data-source licenses;
- conduct analytics, research, and product development, including with respect to user behavior, cohorts, and segments;
- protect the rights, property, safety, and security of the Company, its users, its personnel, and the public;
- cooperate with law-enforcement agencies, regulators, auditors, and other governmental bodies, including in response to subpoenas, court orders, and other legal process;
- effect a corporate transaction, including a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets; and
- for any other purpose disclosed at the time of collection or to which you consent.
Outputs of the Service, including AI-generated summaries, scores, drafts, and charts, may be stored, logged, analyzed, and reviewed by the Company for the purposes described above.
3. Legal Bases (Users in the EEA, United Kingdom, and Similar Jurisdictions)
Where the General Data Protection Regulation, the UK GDPR, or a substantially similar law applies, we rely on the following legal bases to process personal data: (a) the performance of a contract with you or to take steps at your request before entering into a contract; (b) our legitimate interests in operating, maintaining, securing, and improving the Service; (c) compliance with legal obligations to which we are subject; (d) your consent, where required; and (e) the protection of the vital interests of you or another natural person.
4. How We Share Information
We may share information with the following categories of recipients, in each case subject to appropriate contractual or legal safeguards:
- Service providers and processors acting on our behalf to host, operate, analyze, secure, and improve the Service (including cloud-infrastructure providers, analytics vendors, communication tools, payment processors, identity vendors, and AI-model providers);
- Professional advisors, including lawyers, accountants, auditors, and insurers;
- Authorities and third parties in connection with legal process, including law enforcement, regulators, courts, and opposing counsel, where we believe in good faith that disclosure is necessary to comply with applicable law, to enforce our Terms, or to protect rights, property, or safety;
- Successors and acquirers in connection with a corporate transaction, as described above;
- Affiliates under common ownership or control with us;
- Account administrators and workspace owners with whom you share a workspace, team, or subscription; and
- Other recipients with your consent or at your direction.
We do not "sell" personal information in the traditional sense of exchanging it for money. Some disclosures to analytics or advertising partners may nonetheless qualify as a "sale" or "sharing" under certain U.S. state privacy laws; if so, we will honor opt-out requests as described in Section 8 below.
5. Cookies and Similar Technologies
We and our service providers use cookies, pixels, local and session storage, and similar technologies to authenticate users, remember preferences, analyze usage, secure the Service, and measure performance. Some of these technologies are strictly necessary for the Service to function; others support analytics and product improvement. You may configure your browser to reject cookies or to alert you when cookies are being sent, but some features of the Service may not function properly without them.
We do not currently honor "Do Not Track" signals. Where a legally recognized opt-out mechanism (such as the Global Privacy Control) is received, we will treat it as an opt-out request under the laws that recognize it.
6. Data Retention
We retain personal information for as long as is reasonably necessary for the purposes described in this Privacy Policy, including to provide and improve the Service, to comply with legal obligations (including tax, accounting, election-law, and litigation-hold requirements), to resolve disputes, and to enforce our agreements. We may retain de-identified, aggregated, or anonymized information indefinitely. When no longer needed, information is deleted or archived in accordance with our retention schedule, subject to applicable backup and disaster-recovery cycles.
7. Security
We implement commercially reasonable administrative, technical, and physical safeguards designed to protect the information we process. No method of transmission or storage, however, is perfectly secure, and we cannot guarantee the security of any information. You are responsible for maintaining the confidentiality of your credentials and for the security of any device you use to access the Service.
8. Your Rights and Choices
Depending on your jurisdiction, you may have rights with respect to your personal information, including the right to access, correct, delete, port, or restrict the processing of such information, and to withdraw consent or opt out of certain activities. To exercise these rights, please contact us at hello@constituencydata.com. We will respond in accordance with applicable law. We may require you to verify your identity before processing a request, and we may decline requests where permitted by law.
California residents. The California Consumer Privacy Act (as amended by the California Privacy Rights Act) gives California residents certain rights, including the right to know what personal information we collect, to delete or correct such information, to opt out of "sales" or "sharing," and to limit the use of "sensitive personal information." To exercise these rights, contact us as described above. You may also designate an authorized agent.
Nevada residents. You may opt out of certain sales of covered information by contacting us at the email address above.
EEA, UK, and similar jurisdictions. You have the right to lodge a complaint with your local supervisory authority if you believe your rights have been violated.
9. Children
The Service is not directed to individuals under the age of eighteen (18), and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without appropriate consent, we will take steps to delete it.
10. International Data Transfers
We operate in the United States and may store, process, and transfer information in the United States and in other countries where our service providers operate. These countries may have data-protection laws different from those in your jurisdiction. Where required by law, we rely on recognized transfer mechanisms, such as standard contractual clauses, to safeguard such transfers.
11. Third-Party Links and Services
The Service may contain links to, and integrations with, third-party websites and services we do not control. This Privacy Policy does not apply to third-party sites or services, and we are not responsible for their content or practices. Please review their privacy policies before providing them with information.
12. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will update the effective date above and, where required by law, provide additional notice. Your continued use of the Service after an update takes effect constitutes your acceptance of the updated Privacy Policy.
13. Contact
Questions about this Privacy Policy or about our privacy practices may be directed to:
America First LLC
Attn: Privacy
Email: hello@constituencydata.com