Last Updated: May 24, 2018
ILOBBY LLC (“Company,” “we,” and “ our”) collects, uses and shares personal data when using
this website https://www.ilobby.co (the “Site”) together
(the “Services”). Please read the following information
carefully to understand our views and practices regarding your personal
data and how we will treat it.
Particularly Important Information
Must Read Sections:
We draw your attention in particular to the sections entitled “International Data Transfer” and “ Your Rights.”
Changes to this Policy:
We will post any modifications or changes to the Policy on our Site. We
reserve the right to modify the Policy at any time, so we encourage you to
review it frequently. The “Last Updated” legend above indicates when this
Policy was last changed. If we make any material change(s) to the Policy,
we will notify you via email and post a notice on our Site prior to such
changes(s) taking effect.
Purposes of Processing
What is personal data?
We collect information about you in a range of forms, including personal
data. As used in this Policy, “personal data” is as defined in the UK Data
Protection Act 1998/the European Data Protection Directive 95/46/EC/General
Data Protection Regulation 2018 and any successor legislation, this
includes any information which, either alone or in combination with other
information we hold about you, identifies you as an individual, including,
for example, your name, postal address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data
protection and privacy laws. We need certain personal data in order to
provide you with access to the Site. If you created a profile/registered
with us, you will have been asked to tick to agree to provide this
information in order to access our services, purchase our products, view
our content. This consent provides us with the legal basis we require under
applicable law to process your data. You maintain the right to withdraw
such consent at any time. If you do not agree to our use of your personal
data in line with this Policy, please do not use our Site.
Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us.
· the personal data you provide when you register to use our Site,
including your name, ZIP code and email address, username and password;
· the optional personal data you provide when you create a debate including
your image, jurisdiction, about me profile, date of birth, political party, gender and list of preferred issues;
· the personal data that may be contained in any video, comment, debate,
argument or other submission you upload or post to the Site;
· the personal data you provide in connection with our rewards program and
other promotions we run on the Site;
· the personal data you provide when you report a problem with our Site or
when we provide you with customer support;
· the personal data you provide when you make a purchase thorough our Site;
· the personal data you provide when you correspond with us by phone, email
Information from Social Networking Sites.
Our Site include(s) interfaces that allow you to connect with social
networking sites (each a “SNS”). If you connect to a SNS through our Site,
you authorize us to access, use and store the information that you agreed
the SNS could provide to us based on your settings on that SNS. We will
access, use and store that information in accordance with this Policy. You
can revoke our access to the information you provide in this way at any
time by amending the appropriate settings from within your account settings
on the applicable SNS, which includes Facebook.
Automated Decision Making and Profiling.
We do not use your personal data for the purposes of automated
decision-making. However, we may do so in order to fulfil obligations
imposed by law, in which case we will inform you of any such processing and
provide you with an opportunity to object.
What are cookies?
We may collect information using “cookies.” Cookies are small data files
stored on the hard drive of your computer or mobile device by a website. We
may use both session cookies (which expire once you close your web browser)
and persistent cookies (which stay on your computer or mobile device until
you delete them) to provide you with a more personal and interactive
experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served
directly by us to your computer or mobile device, which are used only by us
to recognize your computer or mobile device when it revisits our Site; and
(2) third party cookies, which are served by service providers on our Site,
and can be used by such service providers to recognize your computer or
mobile device when it visits other websites.
Cookies we use
Our Site uses the following types of cookies for the purposes set out
Type of cookie
These cookies are essential to provide you with services
These cookies allow our Site to remember choices you make
Analytics and Performance Cookies
These cookies are used to collect information about traffic
We use Google Analytics for this purpose. Google Analytics
You can find out more about how Google protects your data
You can prevent the use of Google Analytics relating to
Social Media Cookies
These cookies are used when you share information using a
You can typically remove or reject cookies via your browser settings. In
order to do this, follow the instructions provided by your browser (usually
located within the “settings,” “help” “tools” or “edit” facility). Many
browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have
been set on your computer or mobile device and how to manage and delete
them, visit www.allaboutcookies.org and
If you do not accept our cookies, you may experience some inconvenience in
your use of our Site. For example, we may not be able to recognize your
computer or mobile device and you may need to log in every time you visit
DO NOT TRACK SIGNALS
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 signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
Using Your Personal Data
We may use your personal data as follows:
· to operate, maintain, and improve our Site, products, and services;
· to manage your account, including to communicate with you regarding your
account, if you have an account on our Site;
· to operate and administer our rewards program and other promotions you
participate in on our Site;
· to respond to your comments and questions and to provide customer
· to send information including technical notices, updates, security
alerts, and support and administrative messages;
· to match you with and your debate issue with constituents, lobbyists and
Representatives on committees;
· with your consent, to send you marketing e-mails about upcoming
promotions, and other news, including information about products and
services offered by us and our affiliates. You may opt-out of receiving
such information at any time: such marketing emails tell you how to
“opt-out.” Please note, even if you opt out of receiving marketing emails,
we may still send you non-marketing emails. Non-marketing emails include
emails about your account with us (if you have one) and our business
dealings with you;
· to process payments you make via our Site;
· as we believe necessary or appropriate (a) to comply with applicable
laws; (b) to comply with lawful requests and legal process, including to
respond to requests from public and government authorities; (c) to enforce
our Policy; and (d) to protect our rights, privacy, safety or property,
and/or that of you or others; and
- as described in the “Sharing of your Personal Data” section below.
Sharing Your Personal Data
We may share your personal data as follows:
Third Parties Designated by You.
We may share your personal data with third parties where you have
provided your consent to do so.
Third Party Service Providers
. We may share your personal data with our third party service
providers who provide services such as data analysis, payment
processing, information technology and related infrastructure
provision, customer service, email delivery, auditing and other similar
services. These third parties are only permitted to use your personal
data to the extent necessary to enable them to provide their services
to us. They are required to follow our express instructions and to
comply with appropriate security measures to protect your personal
. We may share some or all of your personal data with our affiliates,
in which case we will require our affiliates to comply with this
Policy. In particular, you may let us share personal data with our
affiliates where you wish to receive marketing communications from
We may share personal data when we do a business deal, or negotiate a
business deal, involving the sale or transfer of all or a part of our
business or assets. These deals can include any merger, financing,
acquisition, or bankruptcy transaction or proceeding.
We may share personal data as we believe necessary or appropriate: (a) to
comply with applicable laws; (b) to comply with lawful requests and legal
process, including to respond to requests from public and government
authorities to meet national security or law enforcement requirements; (c)
to enforce our Policy; and (d) to protect our rights, privacy, safety or
property, and/or that of you or others.
When we use the term “anonymous data,” we are referring to data and
information that does not permit you to be identified or identifiable,
either alone or when combined with any other information available to a
We may create anonymous data from the personal data we receive about you
and other individuals whose personal data we collect. Anonymous data might
include analytics information and information collected by us using
cookies. We make personal data into anonymous data by excluding information
(such as your name) that makes the data personally identifiable to you. We
use this anonymous data to analyze usage patterns in order to make
improvements to our Site.
Third Party Sites
Our Site may contain links to third party websites and features. This
Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and
we do not accept any responsibility or liability for their websites,
features or policies. Please read their privacy policies before you submit
any data to them. Third party websites include Google +1, Tumblr, Facebook,
Twitter and Pinterest.
User Generated Content
You may share personal data with us when you submit user-generated content
to our Site, including via our debates, arguments, comments, and blogs on
our Site. Please note that any information you post or disclose on our Site
will become public information, and will be available to other users of our
Site and to the general public. We urge you to be very careful when
deciding to disclose your personal data, or any other information, on our
Site. Such personal data and other information will not be private or
confidential once it is published on our Site.
If you provide feedback to us, we may use and disclose such feedback on our
Site , provided we do not associate such feedback with your personal data.
If you have provided your consent to do so, we may post your first and last
name along with your feedback on our Site. We will collect any information
contained in such feedback and will treat the personal data in it in
accordance with this Policy.
International Data Transfer
Your information, including personal data that we collect from you, may be
transferred to, stored at and processed by us and our affiliates and other
third parties outside the country in which you reside, including, but not
limited to the United States, where data protection and privacy regulations
may not offer the same level of protection as in other parts of the world.
By using our Site you agree to this transfer, storing or processing. We
will take all steps reasonably necessary to ensure that your data is
treated securely and in accordance with this Policy.
We seek to use reasonable organizational, technical and administrative
measures to protect personal data within our organization. Unfortunately,
no transmission or storage system can be guaranteed to be completely
secure, and transmission of information via the internet is not completely
secure. If you have reason to believe that your interaction with us is no
longer secure (for example, if you feel that the security of any account
you might have with us has been compromised), please immediately notify us
of the problem by contacting us using the details in Section 17 below.
We will only retain your personal data as long reasonably required for you
to use the Site and/or to provide you with the Services/until you close
your account unless a longer retention period is required or permitted by
law (for example for regulatory purposes).
Our Policy on Children
Our Site is/are not directed to children under 16. If a parent or guardian
becomes aware that his or her child has provided us with information
without their consent, he or she should contact us using the details in
Section 17 below. We will delete such information from our files as soon as
Sensitive Personal Data
Subject to the following paragraph, we ask that you not send us, and you
not disclose, any sensitive personal data (e.g., social security numbers,
information related to racial or ethnic origin, political opinions,
religion or other beliefs, health, biometrics or genetic characteristics,
criminal background or trade union membership) on or through the Site or
otherwise to us.
If you send or disclose any sensitive personal data to us when you submit
user-generated content to our Site, you consent to our processing and use
of such sensitive personal data in accordance with this Policy. If you do
not consent to our processing and use of such sensitive personal data, you
must not submit such user-generated content to our Site.
You may contact us anytime to opt-out of: (i) direct marketing
communications; (ii) automated decision-making and/or profiling; (iii)
our collection of sensitive personal data; (iv) any new processing of
your personal data that we may carry out beyond the original purpose;
or (v) the transfer of your personal data outside the EEA. Please note
that your use of some of the Site may be ineffective upon opt-out.
You may access the information we hold about you at any time via your
profile or by contacting us directly.
You can also contact us to update or correct any inaccuracies in your
Your personal data is portable – i.e. you to have the flexibility to
move your data to other service providers as you wish.
Erase and forget.
In certain situations, for example when the information we hold about
you is no longer relevant or is incorrect, you can request that we
erase your data.
If you wish to exercise any of these rights, please contact us using the
details in Section 20 below. In your request, please make clear: (i)what personal data is concerned; and (ii) which of the above rights you would like to enforce. For
your protection, we may only implement requests with respect to the
personal data associated with the particular email address that you use to
send us your request, and we may need to verify your identity before
implementing your request. We will try to comply with your request as soon
as reasonably practicable and in any event, within one month of your
request. Please note that we may need to retain certain information for
recordkeeping purposes and/or to complete any transactions that you began
prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of
your personal data. If you would like to make a complaint regarding this
Policy or our practices in relation to your personal data, please contact
us at iLobby LLC 325 Sharon Park Drive, #210 Menlo Park, CA 94025 or firstname.lastname@example.org. We will reply to
your complaint as soon as we can and in any event, within 45 days. We hope
to resolve any complaint brought to our attention, however if you feel that
your complaint has not been adequately resolved, you reserve the right to
contact your local data protection supervisory authority, which for the UK,
is the Information Commissioner’s Office.
We welcome your comments or questions about this Policy. You may contact us
in writing at iLobby LLC 325 Sharon Park Drive, #210 Menlo Park, CA 94025
18. EU-U.S. PRIVACY SHIELD
Company commits to cooperate with the panel established by the EU data
protection authorities (DPAs) and comply with the advice given by the panel
with regard to personal data transferred from the EU. Please contact us to
be directed to the relevant DPA contacts.
As further explained in the Privacy Shield Principles, binding arbitration
before a Privacy Shield Panel will also be made available to you in order
to address residual complaints not resolved by any other means. Company is
subject to the investigatory and enforcement powers of the U.S. Federal