Untitled Document

Civic Government Solutions LLC Privacy Policy

EFFECTIVE DATE: May 1, 2023 


Civic Government Solutions LLC (the “Company”) is committed to maintaining robust privacy protections for its Users. By accessing our Website or Services, you agree that you have read, understand, and agree to be bound by this Privacy Policy (“Policy”) and Terms of Use. For purposes of this Policy, “Website” refers to the Company’s website, which can be accessed at https://civicgs.com/.

If you received a message from a Customer through TextOut, and you wish to learn about how TextOut collects and uses your data, see Section V below.

If you have questions about this Policy, see our Contact Information at the end of this Policy.

Table of Contents:

  1. What Type of User am I?
  2. Privacy Terms for Website Visitors
  3. Privacy Terms for Customers
  4. Additional Privacy Terms for All Users
  5. Message Recipient Opt-Out of Customer Messages through TextOut
  6. Privacy Information for California Residents
  7. Contact Info

  1. What Type of User am I?
  2. Please review the privacy terms for your User type. Section IV contains privacy terms for all Users.

    1. “Visitors” use the Website. See Section II for Privacy Terms for Visitors.

    2. “Customers” use our Services as part of a Company Customer Agreement. The Customer Agreement governs use of the Service. See Section III for Privacy Terms for Customers.

    3. “Customer Users” use our Services under the direction of Customers. Customers are responsible for managing their Customer Users. Customers are responsible for their Users’ use of Customer Data. See Section III for Privacy Terms for Customers.

    4. “Message Recipients” use our Messaging Service if they receive a message from our Customers’ Users via our TextOut messaging platform. See Section V for Privacy Terms for TextOut Message Recipients.

  3. Privacy Terms for Website Visitors
    1. Overview
      This section applies to Website Visitors (“Visitors”). By accessing our Website, you agree that you have read, understand, and agree to be bound by this Privacy Policy (“Policy”) and Terms of Use. For purposes of this Policy, “Website” refers to the Company’s website, which can be accessed at https://civicgs.com/. If you are a User located in the European Union, Company is the data controller with respect to the processing of your personal data pursuant to the EU General Data Protection Regulation (“GDPR”).

    2. Collection of Visitor Information
      1. Information You May Provide to Us.
        1. Contact Information – If you submit a request for information or a question through the Website, you may be asked to provide us with basic personal information including your name, email address, phone number, and postal address. We keep records of the communication, the question and/or request you raised, and how it was resolved. If you choose to subscribe to a Company newsletter, engage in a contest, research study, advertisement or other activity offered through the Website or any promotional advertising, we will collect basic contact information from you related to such activity.

      2. Information We Collect Automatically.
        1. Website Usage Information – as you browse the Website, we and our service providers (including Google Analytics) use a variety of Uppercatechnologies, including cookies and similar tools, to assist in collecting information about how you use the Website. This may include information such as your IP address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with links on the Website, landing pages, pages viewed, mobile carrier, information about the device you are using to access the Website, date and time stamp information and other similar information. Google Analytics doesn’t allow the collection of Personal Identifiable Information. We don’t share personal information with Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

        2. Location Information – We collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).

        3. Cookies and Similar Technologies - To collect the Website Usage Information discussed above, we and/or our service providers, use Internet server logs, cookies, tags, SDKs, tracking pixels, and/or other similar tracking technologies. (“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Cookies are used to identify specific users and improve your web browsing experience, but they do not directly identify anyone.)

          Website visitors can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings. Website visitors can opt out of Google Marketing Platform's use of cookies by visiting the Google Marketing Platform opt-out page or the Network Advertising Initiative opt-out page. Website visitors can accept or reject analytics cookies at the notice provided when they first land on the Website.

    3. Use of Information Collected from Visitors
      1. We use the information collected from Visitors for a variety of purposes including to:
        1. Communicate with you about promotions, offers, and news about Company. You have the ability to unsubscribe from such promotional communications.

        2. Respond to your requests for information

        3. Maintain, provide, and improve the Website

        4. Help us better understand your interests and needs

        5. Customize the advertising and content you see using remarketing, re-engagement, or similar audiences using third-party vendors, including Google

        6. Engage in analysis and research regarding use of the Website

        7. Prevent or address technical or security issues

        8. Investigate in good faith alleged violations of our Terms of Service

        9. Comply with a valid legal subpoena, request, or other lawful proceeding

      2. Legal Bases for Use of Your Information If you are located in the EU, please note that the legal bases under the GDPR for using the information we collect through your use of the Website are as follows:
        1. Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with the Terms of Service which you accept by browsing the Website)

        2. Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Website; operate our Website; prevent fraud, analyze use of and improve our Website, and for similar purposes)

        3. Where use of your information is necessary to comply with a legal obligation

        4. Where we have your consent to process data in a certain way

    4. Sharing of Visitor Information
      Except as otherwise may be stated in this Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We share the information we collect through the Website with the following:
      1. Affiliates and Subsidiaries. We may share the information we collect within the Civitech family of companies for service purposes only.

      2. Service Providers. We may provide access to or share your information with third parties that use the information only to perform services on our behalf, including without limitation and in accordance with this Policy, processing, analytics, data storage, security, fraud prevention, and other services.

      3. Business Transfers. If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Service can continue to operate. In such a case, your information would remain subject to the promises and commitments contained in this Policy until such time as the acquiring party modifies it. If such transfer is subject to additional mandatory restrictions under applicable laws, Company will comply with such restrictions. You acknowledge and consent that such transfers may occur and are permitted by this Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Policy.

      4. Consent. We may also disclose your information to third parties with your consent to do so.

    5. Data Retention
      We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.

    6. Data Subject Rights
      1. Local legal requirements (such as those in the EU or certain US states) may give you additional rights. If you would like further information in relation to your legal rights or would like to exercise any of them, contact us using the information in the “Contact Info” section at the end of this policy. Your local laws may permit you to request that we:
        1. provide access to and/or a copy of certain information we hold about you

        2. prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)

        3. update information which is out of date or incorrect

        4. delete certain information which we are holding about you

        5. restrict the way that we process and disclose certain of your information

        6. transfer your information to a third party provider of services

        7. revoke your consent for the processing of your information

      2. We will consider requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

    7. Third Party Links And Services
      The Website may contain links to third-party websites and functionalities. If you choose to use these third party services, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Because these third-party websites and services are not operated by Company, Company is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third-parties.

  4. Privacy Terms for Customers
    1. Overview
      This section applies to Customers. The Customer controls the Customer Data. When processing Customer Data of EU data subjects, Company is the data processor. We collect and process such information on behalf of and as directed by the Customer in accordance with and restricted by the Customer Agreement. Please contact the Customer for questions about the Customer’s privacy practices.

    2. Customer
      Responsibilities The Customer’s staff, agents, administrators, users, and volunteers must access and use Customer Data (the information Customers collect, send, provide, or receive from using our Service) only as allowed and described in the Customer Agreement and Customer’s privacy policy. Training of staff, agents, administrators, users and volunteers is Customer’s responsibility.

    3. Collection and Use of Customer Information
      The collection, processing and storage of Customer Data is governed by the Customer Agreement. If you choose to connect to third-party integrations through our Services, these third parties may allow us to have access to and store additional information as it relates to your use of the Service. If you initiate these connections, we will share information about you only that is required to enable your use of the third-party integration. By enabling these connections, you authorize us to connect and access the information provided through these connections, and you understand that the privacy policies of these third parties govern such connections.

  5. Additional Privacy Terms for All Users
  6. The following information about Company’s privacy practices apply to all users of Company’s Website and Services.

    1. Changes To Our Privacy Policy
      We may update this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this document, please review the Policy periodically. If we make a material change to the Policy, we will comply with applicable legal requirements regarding providing you with notice sent to the email address on your account. If you object to any changes to this Policy, you may discontinue visiting the Website and/or suspend usage of our Service.

    2. How We Protect Your Information
      Company takes technical and organizational measures to protect your information against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure, and thus we cannot ensure or 100% warrant the security of that information. In the event any information under our control is compromised as a result of breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

    3. Data Storage and Transfer
      Your information collected through our Website and Services may be stored and processed in the United States or in any other country in which Company, its subsidiaries, affiliates, or service providers maintain facilities.

    4. Marketing Practices
      If you receive email from us, we may use certain analytics tools to capture data such as when you open our message or click on any links our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns. You may instruct us not to use your contact information to contact you by email, mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us at the “Contact Info” section below. For email messages, you can unsubscribe by following the instructions at the bottom of the emails. For Twitter advertising, you can opt out within your Twitter settings by following these directions. Regardless of your request, we may still use and share certain information as permitted by this Policy or as required by applicable law. For example, you may not opt-out of certain operational or service-related emails.

    5. Aggregated and De-Identified Data
      We may aggregate and/or de-identify information collected through the Website and Service so that such information can no longer be linked to you or your device (“Aggregated Statistics / De-Identified Information”). We may use Aggregated Statistics/De-Identified Information for any purpose, including without limitation for research, analytics, and marketing purposes, and may also share such data with any third parties, including partners, affiliates, service providers, and others.

    6. Combined Information
      You agree that, for the purposes discussed in this Policy, we may combine the information that we collect through the Website and our Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy. If, however, the collection of any information about you is governed by a Customer Agreement, information will only be combined and used in accordance with such Customer Agreement and the sections of this Policy applicable to Customers.

    7. Cookies
      You can control the use of cookies in your own browser settings. Most browsers will allow you to choose whether or not to accept cookies, disable existing cookies, or automatically reject cookies. Doing so may negatively impact your experience using our Services, as some features on our Services may not work properly. Depending upon your device and/or operating system, you may not be able to delete or block all cookies. The following links explain how to access your cookie settings in various browsers:
      1. Cookie settings in Firefox
      2. Cookie settings in Internet Explorer
      3. Cookie settings in Google Chrome
      4. Cookie settings in Safari (OS X)
      5. Cookie settings in Safari (iOS)
      6. Cookie settings in Android

    8. Children’s Privacy Company’s Website and Services are not directed to anyone under the age of 13. Company does not knowingly collect or solicit information from anyone under the age of 13. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at the Contact Info below.

  7. Message Recipient Opt-Out of Customer Messages through TextOut
  8. We enable our Customers to send text messages through our TextOut platform. Individuals who receive a message (“Message Recipient”) from a Customer may opt-out of receiving messages from the Customer’s program(s). To automatically unsubscribe from any TextOut Customer texting program, Message Recipients may respond by texting STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT or similar words that constitute an opt out under the best practices issued by the Cellular Telecommunications Industry Association (CTIA). The Customer is responsible for unsubscribing the Message Recipient who may reply with messages indicating the Message Recipient wants to be opted out.

    Opt-outs are tracked separately for each TextOut Customer, so unsubscribing from one TextOut Customer will not unsubscribe you from messages from another TextOut Customer. To be globally opted-out of messages from all TextOut customers, Message Recipients may contact us using the information in the “Contact Info” section at the end of this policy.

    We receive target contact (Message Recipient) information from our Customers, and share it, via our Service platform, only with them and their agents. We do not share message content information with third parties other than with third-party processors as part of supplying our application or service.

  9. Privacy Information for California Residents
  10. If you are a California resident, California law requires us to provide you with additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

    1. Categories of Personal Information we Collect
      Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we may collect are:
      1. Identifiers (such as name, address, email address)

      2. Internet or other network or device activity (e.g., User browsing history or Service usage);

      3. General geolocation information (e.g., approximate location based on IP address);

      4. Professional or employment related data that you may share with us

      5. Biometric information (e.g., if you participate in a sales or training call and do not opt-out of call recording);

      6. Inference data about you (e.g., the additional Services we think would be of most interest to you);

      7. Commercial information (such as transaction data); and

      8. Other information that identifies or can be reasonably associated with you.

    2. How we Use and Share these Categories of Personal Information
      We use and share the categories of personal information we collect consistent with the business purposes we discuss throughout this Policy, and dependant upon which type of Company user you are. The CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months from the effective date of this Policy.

    3. Your California Privacy Rights
      CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
      1. Inform you about the categories of personal information we collect or disclose about you; the sources of such information; the business purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Policy.

      2. Provide access to and/or a copy of specific personal information we hold about you.

      3. Delete certain personal information we have about you.

    We are not required to retain any personal information about a person collected for a single one-time transaction if, in the ordinary course of business, that information about the person is not retained. We are not required to re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information.

    The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. Certain information may be exempt from such requests under California law. For example, we need certain information in order to provide Services to you. We also will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, verifying your name and email address. You are permitted to designate an authorized agent to submit certain requests on your behalf. We may follow up with you to verify your identity before processing the authorized agent’s request. If you would like to exercise any of your rights under California law with respect to your personal information, please contact us at the support address below.

    Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

  11. Contact Info
  12. To contact us, please email support@civicgs.com.