‍Wave Michigan is an online, cloud-based service platform that provides individuals and organizations the ability to contribute to, organize, and manage their causes (collectively, the “Services”). This Privacy Policy is intended to comply with all applicable Michigan data protection laws. (except, please note that the services offered through Wave Michigan are offered only in Michigan, and as such, are not subject to foreign data protection laws).

This Privacy Policy details how we collect, use and share personal information in providing our Services.

For purposes of this Privacy Policy, we break down our users into three categories that align with how we handle their personal information:

How we refer to these individuals in the Privacy Policy	How these individuals interact with Wave Michigan	Examples	Our relationship with these individuals
Wave Michigan Users	Individuals who interact directly with our Services	A volunteer who signs up for an event An individual who signs up with Wave Michigan to learn about opportunities to participate in political campaigns	We have our own, direct relationship with Wave Michigan Users
Customers	Representatives of our prospective and existing Customers	A representative of an organization that uses Wave Michigan to manage donations ‍A company representative who requests a demo from Wave Michigan	We have our own, direct relationship with Customers
Customer End Users	Individuals who are our Customers’ users	An individual, such as a company's employee, who contacts voters using Wave Michigan ‍A volunteer who signs up for a political campaign that uses Wave Michigan to organize	Wave Michigan processes the personal information of Customer End Users pursuant to agreements with our Customers – as a “services provider” or “processor.” Our Customers’ use and sharing of this information is governed by their own privacy policies.

Information you provide to us. Personal information you may provide to us through the Services or otherwise includes:

Contact information, such as your first and last name, professional title, business affiliation and address, email address, and phone number. First and last name, and email address, are required to access Wave Michigan's Services.
Biographical information, such as your age and gender, political and professional affiliations, interests in charitable causes, and occupation. This information is not required to access Wave Michigan's Services.
Event information, including where and when the event you sign up for through our Services is taking place, when you signed up for the event, the organizations affiliated with the event, the organization promoting the event, whether or not you actually attended the event, and any feedback you provide about the event.
Payment and transaction data that our payment service providers collect to process your payments, such as your donations or contributions to the political candidate or nonprofit cause of your choice. We do not store payment card numbers on our systems. The information you provide in connection with your purchases is handled by our third-party payment processors, such as Stripe or Plaid, in accordance with their terms of service and privacy policies.
Transaction history, including your donations or other engagement history.
Communications that we retain from any support requests you submit, and questions you may send us about marketing, job opportunities, etc.
Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with those communications.
Information from cookies and other automated technologies, such as information about the devices you use to engage with our Services, and online activity data. For more details about the technologies we use, the categories of information we collect, and how we use this information, please review our Cookie Policy.
Other information about Customer End Users that we may collect which is not specifically listed here, but which we contractually agreed to collect with each Customer. If applicable, please contact your employer or the organization that contracts with Wave Michigan to request a full list of personal information that we collect on their behalf, in addition to the information described above.

Third party sources. In certain cases, we combine personal information we receive from you with personal information we obtain from other sources, including:

Third parties, such as business data providers and public databases. For example, we may obtain information from corporate partners if you are using our Services through a corporate partner program, or from advocacy organizations that use our Services to manage their events. We also may obtain information from public records in order to conduct due diligence or fraud prevention checks, or to supplement your profile.
Distribution lists. To engage in an email, SMS, or calling campaign, our Customers may upload a distribution list that provides us information about their donors or constituents (such as their names, email addresses, and mobile phone numbers). We use and process this information to provide the requested services in accordance with our Customer agreement and this Privacy Policy.
Social media platforms. We may receive information about your activity when you follow us on social media and networking platforms such as Facebook or Twitter. Additionally, if you access our Services through a social networking site or a third-party login service (such as Single Sign-On (SSO) or Google), we may collect information about you from that third party that you have made available via your privacy settings.
Third-party integrations. Should you choose to integrate a third-party product within our Services, such as Google Sheets or Google Drive, we will ask you to grant us permission to view and/or download, as applicable, your Google Sheets or Google Drive. This allows us to configure your integration(s) in accordance with your preferences. We do not use this information for any other purpose.

HOW WE USE PERSONAL INFORMATION

Below is a description of all the possibilities of how Wave Michigan uses personal information, which may be limited under the applicable agreements signed directly by Wave Michigan with its Customers.

A. WAVE MICHIGAN USERS To fulfill our contractual obligations to you, we use personal information to:

Facilitate your engagement with us and our organizations; and
Process your donations and complete your other transactions.

We may also use personal information for the following legitimate business interests:

Recommend opportunities to engage with organizations and campaigns that use our Services;
Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages;
Personalize your experiences within the Services; and
Provide support, and respond to requests, questions, and feedback.

B. CUSTOMERS To fulfill our contractual obligations to you, we use personal information to:

Provide you with our Services; and
Complete your transactions.

We may also use personal information for the following legitimate business interests:

Recommend opportunities to engage with other organizations and campaigns that use our Services;
Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages; and
Provide support, and respond to requests, questions, and feedback.

C. CUSTOMER END USERS

On behalf of our Customers, we use personal information to:

Enable our Customers to recruit and engage with Wave Michigan Users;
Provide our Customers with information relating to our products, events, or other business information;
Communicate with Customers and Customer End Users about our Services and your account, including by sending announcements, updates, security alerts, and support and administrative messages;
Provide support, and respond to requests, questions, and feedback;
Provide marketing and advertising on behalf of our Customers, including interest-based online advertising; and
Build donor profiles for our Customers’ internal use through our Social Matching Feature. As directed by our Customers, we enrich our Customers’ email contact lists by appending Customer End Users’ email addresses with social media account information that we obtain from third-party data providers.

D. MARKETING AND ADVERTISING, INCLUDING FOR:

Direct marketing. We use personal information to market our Services to you, and we can do so through websites, events, programs, and other means. We may send you direct marketing communications promoting our Services, events, programs, or other services that we believe are of interest. Recipients can opt out of our marketing communications as described in the Opt out of marketing communications section below.

Where required by law, we will only send users marketing communications with your consent. Otherwise, we will market and advertise our Services on the basis of our legitimate business interests.

Interest-based advertising. We use cookies and similar technologies to engage in interest-based advertising. Please review our Cookie Policy for more information. Where required by applicable law, we will engage in interest-based advertising only with your consent.

E. RESEARCH AND DEVELOPMENT. IT IS IN OUR LEGITIMATE BUSINESS INTERESTS TO ENGAGE IN RESEARCH AND DEVELOPMENT, INCLUDING TO:

Develop new features, products, and services; and
Create aggregated, de-identified, or other anonymous data or analytics.

F. COMPLIANCE WITH LAW, INCLUDING TO:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
Audit our internal processes for compliance with legal and contractual requirements and internal policies;
Enforce the terms and conditions that govern our Services; and
Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

DISCLOSURE OF PERSONAL INFORMATION

How we disclose personal information. Below is a description of all the possibilities of how and to whom Wave Michigan discloses personal information, which may be limited under the applicable agreements signed directly by Wave Michigan with its Customers.

We may disclose personal information to:

Affiliates. All the platforms affiliated with Wave Michigan for purposes consistent with this Privacy Policy. You can opt out of this disclosure as described in the Privacy Rights and Choices section below.
Organizations and campaigns. Charities, nonprofits, and other organizations, including when you seek to engage with opportunities on our platform or when you engage with a specific organization that uses our platform for its causes.
Service providers. Companies and individuals that provide services on our behalf or help us operate our Services (such as hosting, information technology, customer support, email delivery, and website analytics services).
Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Wave Michigan, our subsidiaries or our affiliates (including in connection with a bankruptcy or similar proceedings). Acquirers will be subject to the same terms under this Privacy Policy.

Contact information: No user or customer mobile phone number or email information will be shared with third parties/affiliates for marketing/promotional purposes.

PRIVACY RIGHTS AND CHOICES

Access to account information. You may update, correct, or delete your account information by accessing the account you have established with us on the Services.

Opt out of marketing communications. You can opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. If you do so, you will continue to receive service-related and other non-marketing emails until you cease using our Services linked to those service updates. Please note that Wave Michigan is not responsible for our Customers’ communications sent to you; to opt out of communications you receive from our Customers, please follow the opt-out or unsubscribe options contained in our Customers’ communications.

Opt out of data sharing among Wave Michigan affiliates. You may opt out of data sharing among our affiliate organizations by contacting us at info@wavemichigan.com.

Privacy rights. You have the right to submit requests about your personal information, depending on your location and the nature of your interactions with our Services:

Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
Correction of personal information that is inaccurate or out of date.
Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
Opt out of the processing or sharing of your personal information for targeted advertising. We share personal information with advertising partners that display targeted advertisements to users around the web. You can limit online tracking as described in our Cookie Policy or by contacting us at privacy@wavemichigan.com.
Opt out of the processing or sharing of your personal information for targeted advertising. We share personal information with advertising partners that display targeted advertisements to users around the web. You can limit online tracking as described in our Cookie Policy or by clicking on the “Your privacy choices” link on our website footer.
Appeal our denial of your personal information request by contacting us as set out below.
Additional rights, such as to object to and request that we restrict our use of personal information.

NOTE: WE DO NOT SELL YOUR PERSONAL INFORMATION.

To make privacy-related requests, please contact us at info@wavemichigan.com. We reserve the right to confirm the identity of the individual making a request before we respond to the request and to assess whether these rights apply to you.

To enable us to match our records with your personal information to respond to your request, you must include the following details in your request. If you do not include this information, we may be unable to complete your request:

The name of the Wave Michigan Services you have used -- Wave Michigan
The first and last name you used to access the Services
The email address you used to access the Services

Additionally, applicable law can limit these rights, for example, by prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request. If we decline a request, we will explain why we took that action, subject to legal restrictions.

You are entitled to exercise all rights described in the Privacy Rights and Choices section free from discrimination.

THIRD-PARTY SERVICES

Our Services can contain links to websites and other online services operated by third parties. In addition, our content can be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of or representation that we are affiliated with any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

INFORMATION SECURITY

We employ current industry standard and legally required technical, organizational, and physical safeguards designed to protect the personal information we collect.

Member States, Switzerland, and the United Kingdom (“UK”), please see Wave Michigan’s Data Processing Addendum (“DPA”) at here.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents or Customers, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a request as set out in the Privacy Rights and Choices section above or by written request to info@wavemichigan.com.

Wave Michigan may transfer personal information to third parties as described in this Privacy Policy. Wave Michigan maintains contracts with its third-party service providers restricting their access, use, and disclosure of personal information in compliance with our obligations under the DPF Frameworks. Wave Michigan may be liable if these third parties fail to meet those obligations and we are responsible for the event giving rise to the damage.

In compliance with the Principles, we commit to resolve complaints about our collection or use of your personal information.

Wave Michigan may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Wave Michigan’s commitments under the Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.

CHILDREN'S PRIVACY

Our Services are not intended for use by children under 18 years of age If we learn that we or a Customer has collected personal information through our Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.