Last Updated June 29, 2020
eBallot (eBallot, we, us, or our) takes your privacy seriously and is committed to protecting the privacy of the information you share with us when you access and use our websites and/or products. We have created this Privacy Statement as a means to disclose how we collect, use and disseminate personal information you may provide us. It also describes your choices regarding use, access and correction of your personal information. This Privacy Statement applies to all of our websites, including, without limitation: https://eballot.com, https://eballot.io, https://eballot.vote, https://eballot4.votenet.com, and https://eballotuv.votenet.com, each referred to herein as a “Site” and collectively the “Sites.” This Privacy Statement also applies to our products (“Products“), including the Ballot Administrator’s Software Application, and describes the data collected on the Products for which we are the data processor and how we may use that data. The use of information collected through our service shall be limited to the purpose of providing the service for which our customer has engaged eBallot.
Effective as of March 13, 2019
eBallot (owned by Votenet Solutions, Inc.) is a leading provider of online voting applications which enable our customers to design, host and implement online votes, ballots and surveys. Our customers are individuals and organizations who purchase the right to use our voting software application platforms. We have a contractual, business relationship with our customers. These customers are referred to as “Administrators” or “Data Controllers” because they determine and control the subject matter, content and information collected for a vote, ballot or survey. The Administrators also determine and control who is invited to vote. We process that information through our voting platform using software technology that we’ve developed. The persons who vote, cast a ballot or participate in a survey are “Participants.” If you are invited to vote, cast a ballot or participate it is because you have been selected by the Administrator, our customer, most likely because of a relationship you have with the Administrator. For example, our customer, the Administrator might be a university and you might be a student at the university. If you are just checking out our website and Products, then you are a “Visitor.” No matter what your relationship is to us, we are committed to establishing and maintaining policies and procedures which protect your privacy.
We take your privacy seriously. As a leading provider of online voting software, we are committed to establishing and maintaining policies and procedures which protect the privacy of personal information gathered from our customers, prospects and other visitors to our Sites.
To our EU users, we are committed to complying with the General Data Protection Regulation and partnering with other businesses that share our commitment to privacy and compliance with the GDPR. We will continue to make changes to our policies and practices to protect your privacy and ensure ongoing compliance with the GDPR.
eBallot (and its parent company Votenet Solutions Inc.) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework, and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.
eBallot is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
We are committed to complying with the GDPR. If you have any questions about our compliance please contact email@example.com
How we received your contact information. If you are a Participant and received an invitation to vote, cast a ballot or participate in a survey, we received your email or other contact information from the Administrator.
Protecting the privacy of children is of paramount importance. Therefore, we comply with the Children’s Online Privacy Protection Act (COPPA) regarding the personal information of children under the age of 13 and with respect to children located in the E.U., the General Data Protection Regulation. A summary of our policy regarding children’s privacy is below:
We are provided only information that is reasonably necessary to allow a child to login and use our products in order to cast their vote/ballot. In general, we will obtain from the child’s school or collect the following information:
We do not afford children the ability to make any information that is collected publicly available.
For more detailed information regarding the information we collect, please review the sections below entitled HOW ADMINISTRATORS USE OUR PRODUCTS and HOW INFORMATION IS USED ON THE SITES AND PRODUCTS.
We store a child’s information using reasonable security precautions and for only as long as reasonably necessary for us to complete the applicable vote/ballot and provide the Administrator with its subscribed services. Please see the section below entitled HOSTING PRIVACY for more information about how your child’s information is stored.
Regardless of our precautions, there is always the risk that a third party may impermissibly access a child’s information. If you believe that a third party has obtained your child’s information, please contact us immediately as instructed in this Privacy Statement.
For more detailed information regarding how we store information, please review the sections below entitled HOW ADMINISTRATORS USE OUR PRODUCTS, HOW INFORMATION IS USED ON THE SITES AND PRODUCTS, HOSTING PRIVACY, and HOW WE KEEP YOUR INFORMATION SAFE.
Generally, the information we collect about a child is used in order for the child to access and use our Products. We may also use a child’s information to verify voting results. Administrators may request additional information about a child pursuant to their applicable ballot and may also have access to a child’s information.
For more detailed information regarding how we use such information, please review the section below entitled HOW INFORMATION IS USED ON THE SITES AND PRODUCTS.
We will never sell a child’s information to third parties. Depending upon the circumstances, we may share collected information with (a) law enforcement or others as needed to protect or defend our rights and the rights of others; (b) partners we hire to handle certain activities and technical services; (c) advertisers or third parties with whom we may partner to provide you additional content, products or services; (d) business partners who jointly offer a service or feature on our Sites; (e) in the event of a corporate transaction; and (f) otherwise with consent.
For more detailed information regarding our information sharing practices, please review the section below entitled HOW INFORMATION IS USED ON THE SITES AND PRODUCTS.
We may use a number of service providers and other such companies in order to provide the services offered through our products. These companies may use their own unique identifiers, and their use of these technologies is within their control and not ours.
Our websites and products also may contain links to other sites or links to social media. We are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every web site that collects personally identifiable information.
For more information about these third parties and how you might be able to control how they use a child’s information, please review the section below entitled HOW INFORMATION IS USED ON THE SITES AND PRODUCTS.
Parents and guardians should be aware that, as previously stated, we will not require a child to disclose more information than is reasonably necessary to participate in an applicable vote or ballot. You can at any time access, update and correct any information about your child that we have collected. You may also direct us to delete such information and refuse to allow us to collect any additional information about your child or use such child’s information.
For more detailed information regarding your control over a child’s information, please review the section below entitled HOW YOU CAN MAKE CHANGES AND HOW WE MAKE CHANGES. You can always contact us regarding the information we collect by utilizing the information referenced in the “How to Contact Us” section above.
Parents and guardians should also be aware that schools where their children attend have the ability to disclose certain personal information about students pursuant to the Family Educational Rights and Privacy Act (FERPA). For more information on what a school can and cannot disclose with and without parental consent, you should visit the following website: http://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html.
If you believe we have unlawfully or improperly stored personal identification information about a child under the age of 13, please contact us via the information listed above in the “How to Contact Us” section so that we may investigate and delete any such information.
Administrators, as required by the nature of their relationship with Participants and reason for their ballots, may collect personal information from Participants, such as names, addresses, telephone numbers, email addresses, membership status/ID or other identifying numbers, passwords or other personal codes or information which can be used in combination to collect information of a personal nature, and may provide this information to eBallot in a list of eligible voters prior to the start of a ballot/voting event. None of this personal information shall be used for any promotional purposes, or anything beyond servicing Administrator’s requests for ballot services.
When you access a ballot created on eBallot as a Participant, we record information such as the date, time and name of the ballot your computer accessed. We will also collect your computer’s IP address.
Administrators or authorized eBallot technicians may upload spreadsheets that include personal information to generate Participant records in the eBallot system to create user accounts. Such information might include a student number or member number, or other personal information such as a birth date or email address to serve as a username or password. We require Participants to login to our site with login codes that are provided via email, mail or other communication methods by either Us or the Administrator. This login requirement is to ensure the visitor is a valid Participant and to determine which valid Participants have submitted a ballot.
We retain a Participant’s information only for as long as it takes us to fulfill our obligations to the Administrator. Administrators using eBallot Products are forbidden from collecting financial information, such as credit card numbers, credit card PIN numbers or other critical information which enables financial transaction authority or privileged security access to any other system. We require that Administrators who control data of persons in the European Union comply with the EU General Data Protection Regulation.
If you are simply visiting our website and are not an Administrator or Participant, we collect your IP address.
We will not attempt to access ballot results at any time, unless (a) you explicitly instruct us to do so during a training session or during a customer service inquiry, (b) we are required to do so by judicial or administrative subpoena, warrant or court order, (c) it is in order to protect the safety of our employees, customers, or the public, or (d) it is to protect our legal rights. We may disclose general turnout statistics about your vote in a case study or marketing document if this information has been requested by the Administrator and approved for publication.
Administrators are solely responsible for the content of the ballots or votes, and we do not control the theme or questions asked. We do not own the contents of your ballot/vote. When you publish your ballot on our servers, we will provide you with a unique URL. We will not provide this URL to any other individuals or parties unless they are authorized business partners who require this information to service your account. In order to enhance response rates, we record if and when a Participant has completed their ballot and if and when a Participant has received an email reminder.
We acknowledge that Participants have the right to access their personal information. eBallot has no direct relationship with the Participant whose personal data it processes. A Participant who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to their Administrator. If requested to remove data we will respond within a reasonable and any legally mandated timeframe.
Administrators, as your data processor, we make available to you this Privacy Statement so that you can better understand our data practices and whether they are consistent with privacy notices you have made available to your Participants. If you receive a data-access request from a Participant about whom we host data and you would like our assistance in responding to that request, please contact us as described below. We will respond to requests within 30 days of receipt.
We will not share any Participant data collected by us with third parties except as expressly provided below [link to sharing section], unless the Administrator directs us to do so and has the appropriate authorization to do so. We may transfer personal information to companies that help us provide our service. These companies are authorized to use personal information only as necessary to provide services to us.
These services may include:
Transfers to subsequent third parties are covered by the service agreements with our customers (Administrators).
We will retain personal data we process on behalf of our Administrators for as long as needed to provide services to our Administrators. eBallot will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We collect information for Administrators, and have no direct relationship with the Participants whose personal data we process. If you are a Participant and would no longer like to be contacted by one an Administrators, please contact the Administrator that you interact with directly.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other information we collect about you.
We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
We never sell information about Participants or information provided by Administrators or website Visitors. We also do not use or share the personal information you provide to us online other than as described below without first giving you a chance to opt out, or otherwise prohibit such unrelated uses. We will not sell any of your personal information. We do not supplement personally identifiable information with information from any other sources.
We use the personal information you provide to us online as follows:
For any of the uses of your information that we describe above, you may opt out and forbid our use of the information for that purpose, by calling, mailing, or emailing us. For our contact information, please see the “Contact Us” section of this Privacy Statement. The only information a user cannot opt out of is service updates, which are important notices about the status of the Products and considered a part of the Service. You can also opt-out of secondary emails by following the ‘unsubscribe’ instructions present in each email we send out.
We do not sell personal information. We also do not share your information with any third parties except under the following very limited circumstances:
Voter Information with Administrator: Our business is to provide tools allowing you and your organization to perform online voting. Accordingly, we allow Administrators to view information about participation and turnout gathered in response to the elections/votes conducted.
As you Explicitly Allow: We may view information about Participants as you provide it prior to the ballot/vote or explicitly allow us to.
Agents Acting on Our Behalf: We may share some of your information with other business partners who provide us with technical services. They will be granted access to only that information which is necessary for them to do their jobs. Any agents to whom we grant access to personal information are contractually barred from using or releasing that information outside of the specific task we have asked them to perform. We have various agreements, policies, safeguards and certifications to ensure that these agents do not sell, distribute or use this information.
Credit Card Services: We use an integrated third party service to process credit cards. Our Site will capture your credit card information and submit it directly to the third party service without storing it on our systems. Please visit www.stripe.com to learn more about their privacy and security features.
For Legal Reasons: We may disclose your information pursuant to judicial or other government subpoenas, warrants, orders, bankruptcy proceedings or similar legal process. We may also disclose your information if it is required to comply with the law, or with legal process served upon us, defend our legal rights or our property, or to act in urgent circumstances to protect the personal safety of our clients, employees, partners, or members of the public.
Our website contains links to other sites. We cannot control the privacy practices of such other sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every web site that collects personally identifiable information. This Privacy Statement applies solely to information collected by our website, Sites or our Products.
Our website includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share button or interactive mini-programs that run on our Site. These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy statement of the company providing it.
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Our blog is managed by Hubspot. You may be required to register to post a comment. We do not have access to or control of the information posted to the blog. You will need to contact or login into the third party application if you want the personal information that was posted to the comments section removed. To learn how the Hubspot uses your information, please review their privacy statement at www.hubspot.com.
We post customer testimonials on our website which may contain personally identifiable information such as the customer’s name. We obtain the customer’s consent to post their name along with their testimonial prior to posting the testimonial.
All votes are encrypted. When a ballot is set to “anonymous,” no one can see how you voted. Ballots/votes that are set to “not anonymous” will allow the Administrator to see how you voted. Information about how a Participant voted will never be provided to any person or entity outside of Votenet Solutions, Inc. and its business partners unless otherwise provided by the Administrator.
Administrators will be able to see whether or not you have voted in any ballot/vote, including anonymous ballots, where no one will be able to see how you have voted.
eBallot does not maintain any physical servers or storage systems of our own. We partner with Amazon Web Services, Inc. for our computing power, database storage and content delivery. We do not have access to our partners’ physical servers or storage systems. To learn more about their privacy practices and security systems visit www.aws.amazon.com.
Additionally, eBallot allows access to its Products and databases only to eBallot personnel or authorized agents of eBallot who have a demonstrated need to access the Products or databases for a particular task related to the operation or provision of our Products.
Our website, Sites and our Products both have security measures in place to help protect against the loss, misuse, and alteration of the data under our control. We use Secure Socket Layer (SSL) technology to protect information using both server authentication and data encryption to help ensure that your information is safe, secure, and available only to you. We also implement an advanced security method based on dynamic data and encoded session identifications, and host our website, and our Products, in a secure server environment that uses firewalls, passwords, and other advanced technology to prevent interference or access from outside intruders. We train and monitor any employee that has access to personal information. Finally, we provide unique user names and passwords that must be entered each time a Participant or Administrator logs in to our Products. These safeguards help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of your information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
You can change your password by selecting “Settings” on the menu for your particular Products application and setting a new password there. Upon request we will provide you with information about whether we hold any of your personal information. To get a complete record of the personal information associated with your account, to change any information, or request that we delete your account, please contact us by email at firstname.lastname@example.org. If you request a change to your personal information, or you request us to delete your account, we will make the change or delete your account within 30 days after we receive your request.
We offer our visitors and customers a means to choose how we may use information provided. If, at any time after registering for information or ordering our Products, you change your mind about receiving information from us or about sharing your information with third parties, send us a request specifying your new choice. Simply email, call or write us. Our contact information is located in the “Contact Us” section at the beginning of this statement.
From time to time we send promotional materials by email, as described above in “The Way We Use Information.” Any email you receive from us will include an “unsubscribe” link that you can use to prohibit us from sending any additional information, and our postal address.
We will retain your information for as long as your account is active or as required to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at email@example.com. In most cases, we will delete your information within thirty (30) days of the date your account is cancelled or terminated. Accounts that are inactive for more than 12 consecutive months will be deemed terminated. However, we reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will occasionally update this Privacy Statement to reflect changes in our services and customer feedback. When we post changes to this Privacy Statement, we will revise the “last revised” date at the top of this statement. If there are material changes to this Policy Statement, or material changes in the way we use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing them, and giving you the option to opt-out of the new policy or procedures, or by sending you a notification of the changes directly, prior to implementing them through email. We encourage you to periodically review this Policy Statement to stay informed on our privacy practices.
We welcome your comments regarding this Privacy Statement and our privacy practices. If you have questions about this statement or believe that we have not adhered to it, please contact us. You can contact us by email, by phone, or by regular mail and we shall respond to your query within 30 days.
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