Effective SEPTEMBER 1, 2019

Turning Point Action, Inc. (“Turning Point” in this Privacy Policy) respects your privacy as a visitor to its website and has developed the following privacy policy to inform you about how Turning Point handles your personal information after receiving it.  This Privacy Policy governs Turning Point use of your information both on the Turning Point websites www.tpaction.com and https://www.trumpstudents.org.

Please read this Online Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

This website is not intended for children and we do not knowingly collect data relating to children.

1. Types of Information Collected and Stored

1. Personal Information Summary.

When you engage in activities such as sign up to receive a Turning Point publication, make donations to Turning Point, shop on our website, or otherwise use the Turning Point website, Turning Point may gather your personally identifiable information (“Personal Information”).  

Your Personal Information may generally include, but is not limited to, your name, address, phone number, email address, birthdate, electronic signature, personal identification numbers, IP addresses, mobile device identifiers, geo-location, or any other personally identifying data collected from you by Turning Point or its authorized agents.  

By using the Turning Point website, you agree to allow Turning Point and its agents to gather, store, and share your Personal Information subject to the limits of this Online Privacy Policy.

2. Specific types of data we collect about you.  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2. Contact Data includes billing address, delivery address, email address and telephone numbers.
3. Financial Data.  When you use the Turning Point website to shop or to make donations to Turning Point, Turning Point utilizes third-party payment processors as its agents (“Payment Agents”) to process your payment and provide payment verification to Turning Point concerning your payment.  Turning Point and its Payment Agents utilize systems whereby we substitute a proxy set of identifying information for your real financial information.  Our Payment Agents, which do handle your credit cards and other payment information, are PCI Data Security Standard (“PCI DSS”) compliant.  Turning Point does not collect or store your credit card numbers or other similar financially-related Personal Information and it isn’t exposed more than necessary.  For more information about PCI DSS please visit https://www.pcisecuritystandards.org/about_us/.  
4. Transaction Data includes details about payments to and from you and other details of Turning Point products and services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
6. Profile Data includes your Turning Point donations, Turning Point purchases or orders made by you, your interests, preferences, feedback and survey responses where applicable.  
7. Usage Data includes information about how you use the Turning Point website, products and services.
8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
9. Aggregated Data / Analytics Information.  We also collect, use and share Aggregated Data. In an effort to improve visitors’ experiences on the Turning Point website, Turning Point gathers this Aggregated Data related to individuals’ website visits.  This information is used solely to measure and improve our website and services and to better serve our members and customers.  Turning Point uses aggregate statistical data to compile reports. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as Contact Data, Technical Data, and/or Marketing and Communications Data which will be used in accordance with this privacy policy. This analytics information so gathered is likely to include the following:  

1. Device and network specific information, such as your unique device identifier, operating system and version, the browser you use, your Internet service provider (ISP), and your IP address.
2. Non-personal information, such as language, zip code, area code, location, and the time zone.
3. Turning Point website visit information, such as the domain from which you came to our website or referring links, and details of how you use our website, including but not limited to what webpages you visit on the Turning Point website, as well as downloads, purchases, and orders during the duration of your visit. At times we will track user behavior over time during interactions with the site in order to pursue legitimate business interests, including, but not limited to, troubleshooting technical user issues with site services.

3. Sensitive Information.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. Cookies and Browser “Do Not Track” Notice

1. Turning Point may use cookies on your computer.  A cookie is a small piece of data sent from a website and stored in a user's web browser while the user is browsing that website.  Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user's previous activity.  Third parties that advertise on the Turning Point website do not have access to Turning Point cookies, but they may use their own cookies on your computer.  Advertisers’ use of their cookies and device identifiers is subject to the advertisers’ own privacy policies.  Turning Point does not correlate its use of cookies with your Personal Information.  
2. Turning Point does not respond to browser Do Not Track (“DNT”) Signals.   Turning Point websites may utilize page tags or web beacons to track information related to user visits as a part of Turning Point data analytics processes and user experience customization as described below.  Page tags are small pieces of Javascript embedded in webpages that collect data to help track web traffic on our website.  Web beacons are very small, effectively invisible, graphic images we use to count and recognize users on our website.  Such technologies enable us to improve and customize user experiences while users visit our website.  Turning Point does not correlate its tracking activities through the use of page tags or web beacons with your Personal Information.  
3. Turning Point may employ third party data analytics firms to track and analyze traffic on the Turning Point website, to analyze visitor trends, to determine advertising effectiveness, browser types and usage trends, and to present targeted ads based on anonymous information collected through tracking.  Turning Point’ third party analytics firms, as described in this section, do not receive your Personal Information.
4. Third parties that may advertise on Turning Point websites may have content embedded that sets cookies on a visitor’s browser and/or tracks visitor information that a web browser visited a specific Turning Point website.  Such information may contain a visitor’s IP address.  Third parties may not collect identifying Personal Information from the Turning Point website unless you provide it to such third parties.  
5. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

5. Keeping Information Updated

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

2. Security of Personal Information

Turning Point takes the security of your Personal Information very seriously.  When your Personal Information is stored by Turning Point, we use reasonable and appropriate measures to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction.  Unfortunately, data transmission over public networks cannot be guaranteed to be one hundred percent secure.  While Turning Point will use all reasonable means to protect your Personal Information, Turning Point cannot guarantee the security of your transmissions of such Personal Information, and you use the Turning Point website at your own risk.  If you suspect your Personal Information has been compromised, please notify Turning Point Customer Service using the contact information provided below.  

3. How we Collect Your Personal Information.  We use different methods to collect data from and about you including through the following methods.  

1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications;
4. request marketing to be sent to you;
5. enter a competition, promotion or survey; or
6. give us feedback or contact us.

2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
3. Technical Data from the following parties:

1. analytics providers such as Google;
2. advertising networks; and
3. search information providers.

4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
5. Identity and Contact Data from data brokers.
6. Identity and Contact Data from publicly available sources.

4. How Turning Point Uses and Shares Your Information

1. General Information and Your Rights.  Turning Point limits its use of your Personal Information to the stated purposes for which such information is collected.  In some cases, Turning Point may be required to disclose your Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  You have the right to the following regarding your Personal Information transferred to Turning Point:  

1. To know the types of Personal Information Turning Point collects;
2. To know the purposes for which it collects and uses your Personal Information;
3. To know type or identity of third parties to which Turning Point discloses your Personal Information, and the purposes for which it does so;
4. To access and update your Personal Information; and
5. To know the choices and means Turning Point offers you for limiting the use and disclosure of your Personal Information.

2. Other Turning Point Services.

Turning Point may use your Personal Information to provide services to you upon your request.  Such services may include sending you newsletters and publications, responding to your questions and comments, communicating with you concerning your purchases on the Turning Point website, emailing you updates concerning Turning Point products and services, and personalizing your visits to Turning Point website.  

You may opt-out of the use of your Personal Information as described in this Section by contacting Turning Point Customer Service using the contact information provided below.  

3. Turning Point Internal Data Sharing 

Turning Point may also share your Personal Information with other Turning Point offices or Turning Point subsidiaries in the country in which you reside and in other countries.

4. Information Sharing with Third Parties

1. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. Turning Point may utilize third-party service providers that process your Personal Information solely on Turning Point’ behalf (“Agents”).  When Turning Point transfers your Personal Information to its Agents, your Personal Information will be used only for limited and specified purposes.  Turning Point will take reasonable and appropriate steps to ensure that its Agents process your personal information in a manner consistent with the organization’s obligations under the Principles.  Turning Point remains responsible and liable if the Agents that Turning Point engages to process your Personal Information on Turning Point’ behalf do so in a manner inconsistent with this Online Privacy Policy, unless Turning Point proves that it is not responsible for the event giving rise to the damage.
3. Turning Point uses consultants and third party vendors, such as testing centers and Testing Delivery Partners, and may share your Personal Information with such consultants and vendors, if necessary, for delivery or administration of the Turning Point Certification Programs.  All parties with which Turning Point shares your personal information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.  Turning Point’ agreements with third parties provide that third parties will delete your personal information upon request.  
4. Turning Point may share aggregated demographic information with our partners and advertisers. This is not linked to any Personal Information that can identify any individual person.
5. Turning Point uses outside third parties to ship orders and financial service-oriented third parties to bill users for goods and services.  All parties with which Turning Point shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.
6. Turning Point may partner with third parties to provide other specific services, including, but not limited to registration for Turning Point conferences and other Turning Point programs and educational materials.  When the user signs up for these services, we may share names, or other contact information that is necessary for the third party to provide these services.  Turning Point may auto-populate forms utilized by these third parties with data contained in Turning Point managed cookies. These third parties are not allowed to use your Personal Information except for the purpose of providing these services.  All parties with which Turning Point shares your Personal Information are bound by confidentiality and data transfer agreements consistent with this Online Privacy Policy.

5. Other Possible Disclosures.

In addition to the other disclosures stated herein, Turning Point may share your information in the following ways:

7. To comply with applicable laws, Internal Revenue Service and other regulations, legal processes, or government enforced orders,
8. To enforce applicable terms of service, protect our legal rights or defend against legal claims,
9. To defend, prevent, take action, and otherwise address security or technical issues, as well as suspected or potential fraud,
10. To guard against harm (whether actual or potential) to the legal rights, property or safety of Turning Point, our visitors or the general public as required or permitted by law.

5. Turning Point Purposes In Using Personal Information

We have set out below, in a table format, a summary of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

6. How to Access or Change Your Personal Information

1. To review or make changes to the content of your Personal Information, or to request that we limit the use of your Personal Information, you may make changes and updates by logging into your user profile and making such changes.  Alternatively, you may request such changes by contacting Turning Point Customer Service using the contact information provided below.  
2. In your request, clearly state what information you would like to have changed or updated.  Turning Point will try to comply with your request as soon possible.
3. The deletion of Personal Information and other changes to the data retained by Turning Point as described above may result in the deletion or limitation of other services Turning Point provides, including, but not limited to, maintaining and making accessible Turning Point certification records. Turning Point may retain certain Personal Information to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce agreements.

7. Notices of Changes to Privacy Policy

In the event of any change to the Turning Point Online Privacy Policy, notice of such changes will be posted on the Turning Point website.  Any changes to this Online Privacy Policy will become effective when we post the revised Online Privacy Policy on the Turning Point website. Your use of the Turning Point website following these changes means that you accept the revised Online Privacy Policy.

8. Contact Turning Point

For any questions, comments, or further information concerning the terms of this Online Privacy Policy, or to request changes to your Personal Information, subject to such limitations as provided herein, please contact:

Turning Point Action, Inc.  Customer Service

[email protected]