Privacy Policy

 

This Privacy Policy (“Policy”) is effective as of 07-01-2021.

This Policy sets forth how Friends of Eli Nicolosi, a(n) Illinois political committee (“we” or “us”), collects and uses the information you provide to us and certain other information that we automatically collect through your access and use of elinicolosi.com (“Website”), which we operate. YOU ACKNOWLEDGE AND AGREE THAT BY USING ANY PORTION OF THIS WEBSITE OR ANY SERVICES OFFERED ON THIS WEBSITE, OR ANY MOBILE APPLICATION WE OFFER, SUCH USE SHALL INDICATE THAT YOU HAVE READ, UNDERSTAND AND THAT YOU AGREE TO OUR COLLECTION AND USE OF THE INFORMATION PROVIDED BY YOU OR AUTOMATICALLY COLLECTED BY US, AS SET FORTH IN THIS POLICY.

If you have any general questions or concerns about this Policy, you may contact us by sending an email with your questions, comments or concerns to [email protected]

MODIFICATIONS TO THIS POLICY

If we decide at any time to change this Policy, we will revise the effective revision date posted at the top of this Policy and we will also notify you by posting a notice of the change prominently on our home page and/or upon the next time you access this Website.

HOW WE COLLECT PERSONAL INFORMATION

There are a variety of ways in which you may submit certain personal information (personally identifiable information) on this Website. We collect the following specific items of personal information (collectively “PII”) that you submit through your use of this Website: your first and last name, your phone number, and your email address.

We may ask our visitors for their email addresses and sometimes for their first and last names in order to provide any newsletters or other materials they have signed up to receive through this Website, from time to time. When you provide this information to us, we collect and store this information and use it as specifically set forth in this Policy.

When you provide any PII through any form contained on this Website in order to contact us or send us a message, we collect and store this information. We may use your email or any other PII you provide as expressly set forth in this Policy.

When you register and create an account with us to use this Website as a registered user, we collect the PII you provide during registration and use it as set forth in the remainder of this Policy.

We collect and store your email address and all PII that you provide during the check-out process when you purchase any products or services sold through this Website. We use this information as set forth in the remainder of this Policy. All credit card or other billing information you submit is only used for payment processing or fraud prevention and we do not share or disclose your credit card or other billing information with third parties except with our third party payment processor. Any specific credit card or billing information will not be kept on our server logs longer than necessary in order to complete any single transaction, unless you elect that we retain your credit card information for future purchases, or pursuant to any recurring fees required to be paid pursuant to any product(s) we sell.

Demographic Information

When you provide your (collectively known as “Demographic Information”, or “DI”) we collect and store all DI. We will generally use this information internally to assist us analyze the profiles of who our Website users are and our web traffic in general. We also may share this information in association with your PII as specifically stated in this Policy.

Personal Information from Children Under 13

Children under the age of 13 are expressly prohibited from submitting or posting any PII on this Website. If it does come to our attention that any child under the age of 13 has submitted any personal information to this Website, we will delete all such information that we have collected immediately. If you are a parent or guardian and you discover that your child under the age of 13 has submitted any of his or her PII without your permission or consent, we will remove the information immediately upon your request. All requests should be made by email and sent to [email protected]. Please include your child’s name and a description of the type of information you think he or she may have submitted to this Website.

HOW WE AUTOMATICALLY COLLECT NON-PERSONAL INFORMATION

When you access our Website, we collect and store certain non-personally identifying information sent automatically by your browser using standard web server logs and automatic data collection tools such as cookies and web beacons. This information may include your IP address, which may tell us your general location information such as your country and sometimes your city, state and/or zip code, the domain name from which you access our Website, your browser type and language, the pages you access, the date and time you access pages on our Website and your operating system version. We also may determine what technology is available through your browser in order to provide you with the most appropriate version of any of our web pages. For example, we may determine that you have installed a version of Flash, and we will then send you the appropriate Flash version of the web page rather than an HTML page. We may also use this information to redirect you to a different version of our Website if you are accessing our Website through a mobile or similar device.

Device-Specific Information

We may automatically collect device-specific information about your mobile and other devices such as the type of device you are using, any unique device identifiers, mobile network information including phone numbers, device model, manufacturer, screen resolution, device capabilities, service provider, preferred user language and your page views. We do this to help us determine which aspects of the website work best for mobile traffic and which mobile marketing campaigns work best for the business, including mobile advertising, mobile search marketing, text campaigns, and desktop promotion of mobile sites and services.

Geolocation Information

We may collect your actual location data when you access this Website or use any services we offer on this Website. This may include the GPS coordinates of your mobile device or other actual location information from other sources such as through a Bluetooth MAC address, RFID, Wi-Fi connection location, or through cell phone triangulation. Any actual location information we collect other then through detection of your IP addres is collectively referred to as “Location Information” throughout this policy. You may at any time disallow our application to use your location by turning this off at the device level.

Cookies & Similar Tracking Use Policy

We along with third parties that assist us to operate this Website may monitor your use of this Website through cookies, web beacons and other “automatic data collection tools.” Unless you have adjusted your browser setting to refuse all cookies, some cookies are placed on your browser immediately as soon as you visit our site. Cookies and similar collection tools are files with a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and transferred to your device. We reserve the right to monitor your use of this Website and track you as described in this Cookies policy by the use of any automatic data collection tools at all times and you consent to the use of these tools when you use and access our Website. This Website uses both “first-party” cookies and “third-party” cookies. First-party cookies are those used by our Website each time you visit our Website. Third-party cookies are cookies that are set by a third-party source other than our Website. We do not have access or control over these cookies. We also use both “persistent cookies” that remain on your device for the period of time specified in the cookie (these cookies are activated each time you visit our Website), and “session cookies,” which allows us to track your actions on this Website during a browser session. Each time you open up a browser window and close the browser window represents a single browser session. All session cookies are created temporarily and are deleted once you close your browser window.

Both the first-party and any third-party cookies used on this Website can be broadly divided into the following categories:

-Necessary cookieshelp make our website usable by enabling basic functions like page navigation and access to secure areas of the website. Our website cannot function properly without these cookies.

-Statistic cookies helps us understand how visitors interact with websites by collecting and reporting information anonymously.

 

First-Party Cookies/Tracking Technologies

User Preferences: We use automatic data collection tools to identify and recognize your browser as a previous visitor to our Website and save and remember any user preferences that may have been set during a previous visit. We store specific user preferences and settings on this Website and/or similar session identifiers to help you navigate and access certain features on this Website. Website Use: We use automatic data collection tools to track and record your Website use and activity data, including the pages you view and how long you spend on each page or portion of our Website, the links you click on, the features of this Website you access, whether you are a new vs. repeat visitor or in order to monitor your interactions with any video or other content that you access on this Website (“Use Information”). This is done primarily for website traffic and general user analysis purposes. We also do this to help measure and research the effectiveness of the features contained on this Website.

Analytics Services

We may use third party web analytics services, such as Google Analytics, in order to collect information about your use of this Website. You may opt-out of Google Analytics by using Google’s Browser Add-on at https://tools.google.com/dlpage/gaoptout.

Behavioral/Interest Targeting: We also use cookies to customize the content we display to you when you are visiting our Website based on your previous Website use and activities.Email Marketing: We may also use clear gifs (imbedded web beacons) to understand whether users read email messages or newsletters and/or click on links contained within those messages or newsletters so that we can deliver relevant content or product offers. Through the use of unique identifiers contained in the URL of the web beacons, we are able to record the exact time that you read our emails, as well as your IP address from tor proxy server. Some emails and web pages may refer to content on another server rather than including the content directly. Requests to the server to send the additional content typically includes the IP address of the requesting computer, the time the content was requested, the type of web browser that made the request and the existence of cookies previously set by that server, which may be linked to a unique tracking “token”.

Retargeted Advertising

We may place ads on third-party websites belonging to any of our cross-marketing partners, affiliates or advertising partners, etc. targeted to you based on your past visits to this Website. We collect and store information regarding which of these websites you visit by using cookies and similar detection tools that identify you uniquely. When we use cookies, these cookies contain a unique identification number that allows our advertising partners/network to recognize your computer and correlate the computer to your online activity within the network. When you visit a website within our advertising network, the advertising network may set a new cookie in your browser or automatically receive a previously set cookie from your computer’s browser. The advertising network then may add information about your web browsing activities within the network to information already collected via the cookie, and may use such information to serve online advertisements that are targeted to your interests, based on your browsing history. If you do not want us to track your information on such third party websites in order to show you targeted ads, you can send an email request to [email protected] with the words “Tracking Targeted Ad Opt-out” in the subject line and specifically request to opt-out of our sharing of this information to these third parties. Please note that this will opt you out of targeted ads from us and any other participating advertising partners, affiliates, etc. If you opt out, you will continue to receive general advertising from us on our Website only, but not targeted to you.

Do Not Track Requests

Your browser may incorporate a “Do Not Track” feature allowing you to tell websites not to track your online activity. We do not respond to “Do Not Track” signals due to technological issues with most browsers’ communications.

Facebook Ad Conversion Tracking. We may use the Facebook Pixel to track whether or not you have clicked on any of our Facebook ads we run from time to time and to track any associated actions you make on our website, including which Facebook ad led to a conversion. Facebook “Custom Audiences” allows us to target our Facebook ads to you and re-market to you based on certain activities you perform on our Website. We may optimize our Facebook ads and automatically show ads to our visitors most likely to make conversions. The Facebook pixel also allows us to send your data to Facebook to match your website actions with you as a Facebook user when you view or click any of our Facebook ads. We report and optimize our Facebook ads for more conversions and we pass unique identifiers such as your email or phone number that we collect from you during your actions on our Website (such as logging-in, registering for an account or checking-out). Whenever you load a page containing a Facebook pixel, the pixel tells Facebook that a conversion event occurred.

You may opt-out of participation in our Facebook Custom Audience by sending an email, from the email address you are opting out of, to . For your opt-out to be effective, you must: (i) place the following text in the subject line of the email – “Opting Out of Facebook.com Website Custom Audience Ads”, and (ii) in the body of the email, include your name and email address. We will forward your name and email address to Facebook.com with a request to delete you from all of our Facebook Custom Audience Ads.

Google AdSense & DoubleClick DART Cookie. We participate in Google AdSense and your website Use Information is shared with the Google advertising network by using the DoubleClick DART cookie, which is a third party cookie used by Google. When you visit a partner’s website and either view or click on an ad, a cookie may be dropped on your browser. The data gathered from these cookies will be used to help better serve and manage ads on the publisher’s site(s) and across the web. When the cookie is set on your browser, it allows Google to gather information about your browser’s interaction with a given ad. To opt-out of this use, please visit https://support.google.com/ads/answer/2662922?hl=en. You can also opt out of some, but not all, of these cookies in one location at the Network Advertising Initiative opt-out website at www.networkadvertising.org/managing/opt_out.asp.

We may also participate in any and all of the following Google Analytics Advertising Features provided by Google: Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. These features use first party cookies (such as the Google Analytics cookie) for connecting the tracking activity performed by Google Analytics and its cookies with the AdSense advertising network using the DoubleClick cookie. We may share your Use Information that we may collect from time to time from your use on this Website. In order to opt-out, please visit https://support.google.com/ads/answer/2662922?hl=en. You may opt-out of the Google Analytics service by using Google’s Browser Add-on available at https://tools.google.com/dlpage/gaoptout.

YouTube. GPS location data is collected by YouTube to track you on different websites to see what videos you watch and how they are used. Learn more about how Google may use this information.

Google Maps. Each time you use Google Maps through our Website or App, your device GPS location data and unique device identifiers (including your Google advertising ID (GAID) via the Google Maps API) is collected and used by Google according to its privacy policy.

Managing Cookies

You can block our cookies or any third-party cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to use all or parts of our site in the manner intended. Your Internet browser allows you to change your cookie settings in the ‘options’ or ‘preferences’ menu of your browser. Please visit the following link for more information on these settings in various browsers: https://www.thewindowsclub.com/disable-enable-cookies-internet-explorer. For even more information about deleting or blocking cookies, please visit: http://www.aboutcookies.org/Default.aspx?page=2

 

Our Data Processors & Subprocessors

A data processor is any third-party that we use to operate this Website or provide our Services to you who has or potentially will have access to or process any personal data you provide to us. These data processors may engage different types of subprocessors to perform various functions. This limited access is incidental to the services being provided by such third parties to us to operate this Website and/or to provide our Services to you and no permission or consent is granted by us to use or disclose this information in any manner other than as necessary to provide the applicable services to us or to facilitate any transactions with you.

In addition, we require all of our data processors and subprocessors to satisfy the requirements of the GDPR in terms of data protection and use, including but not limited to the requirements to:

1. Process personal data in accordance with our documented instructions; and

2. Use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws including the GDPR, in connection with their subprocessing activities; and

3. Provide regular training in security and data protection to personnel to whom they grant access to any personal data; and

4. Implement and maintain appropriate technical and organizational measures, including measures consistent with those to which we may be contractually committed to adhere to relevant to the subprocessors processing of personal data on our behalf; and

5. Promptly inform us about any actual or potential data breaches; and

6. Cooperate with us in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

We use the following data processors:

Infrastructure & Data Storage: We use Liquid Web, LLC to host this Website and store your data on their servers.

Billing & Shipping Agents:When you purchase anything from this Website, the PII you provide, your credit/debit card or bank account information you provide and any shipping information is collected by Square, our third party credit card and payment processor. Any disclosure of this information is necessary to facilitate the specific transaction and will only be used by us for that strict purpose, unless otherwise stated in this Policy. This limited access is incidental to the services being provided by such third parties and no permission or consent is granted by us to use or disclose this information in any manner other than as necessary to provide the applicable services to us and facilitate any transactions with you.

HOW WE USE YOUR INFORMATION

 

Linking (Bundling) Your Website Use Information

We do not combine or link your PII with any Website Use Information or any other information we automatically collect from you.

 

We use your e-mail address to send periodic promotional e-mails to you about our services and products, any new or upcoming products or otherwise related to any products or services we sell. You can opt-out of receiving any promotional emails at any time by either clicking “unsubscribe” in the body of the email communication and following the opt-out procedure contained in the email, or by sending an email to [email protected] and requesting to opt-out of receiving such communications. We may also send direct mailers and send periodic newsletters and/or promotional materials to the physical address you have provided about our services and products, any new or upcoming products or otherwise related to any products or services, but only if you have elected to receive such communications from us. You can opt-out of receiving any mailers or newsletters/subscriptions at any time by sending an email to [email protected] and requesting to opt-out of receiving such communications in the future. Finally, we may send you text messages to any mobile number you provide to us for promotional or advertising purposes, in order to communicate certain necessary information to you or in order to facilitate some transaction with you though this Website. You can opt out of receiving text messages by texting the word “STOP” to any number that sends you text messages from us.

SMS Mobile Consent

WE COLLECT ALL MOBILE NUMBERS PROVIDED TO US AND WILL USE SUCH MOBILE NUMBERS TO SEND SMS/MMS MESSAGES PERIODICALLY ABOUT OUR SERVICES. By registering to use our Services, You consent to and otherwise authorize us to send such SMS/MMS messages to any mobile phone number provided to us by you pursuant to your use of the Services. We will at all times comply with the Telephone Consumer Protection Act (“TCPA”), the Federal Trade Commission Act, all rules and regulations promulgated by the the Federal Communications Commission, the DNC list registry rules (http://www.donotcall.gov) and various state laws, rules and regulations that place restrictions on our SMS or MMS message campaigns. We will include clear opt-out/unsubscribe information on any text messages we send to any mobile numbers provided to us and otherwise adhere to the Consumer Best Practices Guidelines promulgated by the Mobile Marketing Association, if applicable. We agree that any individuals requesting “Do-Not-Call” (“DNC”) status shall immediately be placed on our DNC list and further agree that we will not initiate any subsequent messages to any such individuals.

Administrative/Customer Service Support

We share our files and some PII we collect through this Website directly with third party independent contractors that provide customer support and other administrative services on our behalf. This limited access is incidental to the services being provided by such third party contractors and no permission or consent is granted by us to use or disclose this information in any manner whatsoever, other than as necessary to provide the applicable services to us. We require that each of our contractors agree not to use or disclose any PII or any other information relating to the services we provide, which may be disclosed to or shared with these parties during the course of their duties to us, except as absolutely necessary to perform their duties to us.

 

Do We Sell Your PII?

We make every effort to respect your privacy and we will never sell, license or disclose any of your PII, by itself or bundled with any Use Information or other information you provide or that we collect to any third parties for any purpose not expressly set forth in this Policy without your express written consent. We only share or disclose any PII or other information collected from You as expressly set forth in this Policy.

Cross-Device Data

We track your Use Information across multiple devices you use to access our website and link such information, including the specific device information, to a unique profile we create about you. We may also include certain audio data we record directly from your device microphone or visual data we capture from any device camera.

Web History

We determine whether you have previously visited a webpage by checking how your browser styles the display of a hyperlink, or by exploiting some other feature of your web browser to determine this. This practice is also known as “history sniffing”. For example, we may introduce a script onto your browser that tells us whether you have previously visited a webpage through your browser cache history. We include the history sniffing code within advertisements served to you within our advertising network targeted to you based on your web browsing history. History sniffing allows us to determine whether you have visited webpages that are outside of our advertising network.

Sensitive Targeted Ads

Based upon knowledge of which domains our users have visited through our use of history sniffing, we assign an interest category to our users, which includes sensitive categories (i.e. “incontinence,” “arthritis,” “memory improvement,” “pregnancy-fertility”, “bankruptcy”, “poor credit”, etc.), and we uses this history-sniffing data for behavioral targeting purposes to show you relevant ads based on this categorization. However, before we will use this information to show you targeted ads that we think you may find relevant or that match your interests, you must opt-in to this practice by us. If you do want us to target interest-based ads to you based on such sensitive web history information, please send an email request to [email protected] with the words “Sensitive Ads Opt-In” in the subject line and specifically request to opt-in to be shown these sensitive targeted ads based upon your web history. Please provide us with your first and last name and your email address when opting-out. Once we receive your request, we will immediately cease sharing your information with such third parties.

Social Media Features and Plugins

We may also provide access to services or features on our Website that enables you to share information with certain social networks and interact with us on our social media fan pages or other social media platforms that we may utilize. This may include the Facebook “Like” or share buttons or the Facebook “Comments” feature, social media “follow-us” buttons, etc., all of which are administered via third-party applications or scripts that run on our Website. (For example, Facebook will attempt to track your use on our Website by placing Javascript code through the “like” button and that piece of code then allows Facebook to run a script on your browser which can set cookies and make more tracking requests). Your use of these features may result in the collection or sharing of information about you by these third-party social media websites. This may include collection of your IP address, tracking your use on our Website and other third-party websites containing the same social media features, including the pages you visit, duration, time, etc., through the use of a cookie or other unique identifier placed on your browser by such third-parties. Your interactions with these social media features are governed by the privacy policy of the party that provides the specific feature or application. You should carefully review the privacy policies and settings on those specific social media sites. In addition, these standalone plugins that integrate into our website may also communicate with an external server controlled by the plugin provider as part of their service. We shall, under no circumstances, have any liability to you whatsoever for the information collection and use/disclosure practices of any such third party that has provided or made available any social media feature or other plugin application that you use on our Website.

Your Rights Under the GDPR

Under the General Data Protection Regulation (GDPR), EU citizens (individuals located in the EU during data collection) have the following rights:

1. the right to access stored personal data.

2. the right to rectify errors in your personal data.

3. the right “to be forgotten” and have any stored personal data permanently deleted.

4. the right to withdraw your prior consent to and/or restrict certain uses of personal data we collect.

5. the right to know the source of your personal data collection if informed consent was not given.

6. the right to object to the processing of your personal data in certain circumstances.

7. the right to have your data provided in an electronic, machine-readable format.

If you are an EU natural citizen, please [email protected] contact us in order to exercise any of these rights.

California Resident Privacy Rights

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

1. Right to know what personal data is being collected about you from our Website.

2. Right to know whether your personal data is sold or disclosed by us and to whom.

3. Right to say no to the sale of personal data by us if applicable.

4. Right to access your personal data that we collect from you.

5. Right to request that we delete any personal information about you that we have collected from your use of this Website.

6. You shall not be discriminated against by us for exercising your privacy rights.

If You are a California resident and desire to make such a request, please contact [email protected] Please include the words “California Data Access Request” in the subject line.

Required Disclosures

We may disclose certain PII if: i) requested via a subpoena, court order, or local, state, federal or international law enforcement request to release any such information; or ii) in order to investigate and help prevent security threats, fraud or other malicious activity; or iii) to protect our rights or protect our property, or any or the rights of our customers or other third parties.

Communications

When you visit this Website or send e-mails to us, you are communicating with us electronically. You consent to receive communications from us electronically. You agree that all agreements, notices and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. If you send us an email communication, call us or send a written correspondence for any reason, we may create a file and store your email and other PII specific to you. We generally will maintain a record and keep notes of all communications with you. All messages transmitted by you on this Website or to us shall not be treated as confidential and shall be deemed to be accessible to the general public. You should not transmit any communications or correspondences to us that you intend only the intended recipient(s) read. Notice is hereby given that all messages or electronic data transmitted onto this Website can and may be read by us, regardless of whether we are the intended recipient of any such message(s).

HOW WE PROTECT YOUR INFORMATION

We use reasonable, industry standard security measures in place protecting all Information you provide through this Website. For instance, when you provide any credit card or other billing or shipping information through our checkout process, we encrypt that information during transmission using Secure Sockets Layer (SSL) encryption. We also use reasonable and customary security measures in order to protect against the loss, misuse or alteration of any PII or any other information we collect and store. This includes protecting your information by using a multi-layered firewall based security system. We make no guarantee, warranty or representation that any information you provide through your use of this Website will remain secure at all times from any illegal or unauthorized access of the information by third parties. You agree that we shall not, under any circumstances, be held responsible or liable to you for any damages of any kind whatsoever related to any information or transmissions that are accessed by third parties illegally or without authorization through this Website and/or network. We will report any unauthorized access of your information promptly upon discovery and we will use our best efforts to remedy any security vulnerability that contributed to the unauthorized access.

 

GENERAL INFORMATION

Information Storage And International Transfer

Any PII and all other information which we collect on this Website will be stored and processed in our servers located in the United States. If you reside outside the United States, you consent to the collection, transfer, storage and processing of any information from your country to the United States.

How to Update, Change or View Your Personally Identifiable Information

If you would like to request any changes or updates to any PII you have provided to us, or if you would like to view any information we have collected from your use of this Website, please contact us and request the same by sending an email to: [email protected] Please include the words “Personal Information Request.” If you make any information requests, we will require that you provide proof of your identity, which may include providing us with a copy of a driver’s license, social security card and/or birth certificate. We also reserve the right to require that you sign and provide us with a notarized affidavit verifying your identity before we update or release any information to you.

Successors

Upon any acquisition, merger, sale or other change of control of our business/organization, we reserve the right to transfer any PII you have submitted to this Website as part of the property owned by us to our successor resulting from such merger, acquisition, sale, etc. In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, We reserve the right to transfer your PII to protect any of the our rights or as required by law.