Last Updated: August 22, 2018
The Project On Government Oversight, Inc. (“POGO”, “us”, “we”, or “our”) operates the pogo.org website, delivers newsletters and other content via email, and makes the same or similar content available to mobile users (collectively, “Services”), and we care about your security and privacy.
It also does not apply to websites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third party websites.
If you have any questions, email us at firstname.lastname@example.org or write us at:
Project On Government Oversight
1100 G Street NW
Washington, DC 20005
Attn.: Privacy Counsel
We can also be reached by phone at (202) 347-1122.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve the POGO Services.
Generally, we collect and use information to:
- Deliver relevant content on the pogo.org website
- Send newsletters and emails related to our mission (including fundraising solicitations)
- Accept donations to continue and further our mission
- Gather general usage statistics via Google Analytics to improve the pogo.org website interface, structure, function, and experience
Types of Data Collected
While using POGO Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, POGO-related marketing or promotional materials, fundraising solicitations, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may also collect information on how POGO Services is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of POGO Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
Tracking Cookies Data
Cookies are files with small amounts of data, which may include an anonymous unique identifier to recognize you and your devices across multiple visits. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze POGO Services.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, some portions of POGO Services may not be available for use or able to function properly.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate and enhance POGO Services in various ways, including customizing your experience using the Services and determining the most relevant content to show you.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings so that you don’t have to reenter the same information repeatedly.
Information from Third Parties
We may receive information about you from third parties and combine it with information we receive from or about you. For example:
- Information from social media websites: When you interact with any POGO property page or account on a social media platform, such as Facebook, Facebook Messenger, Twitter, Instagram, Slack, Snapchat, or LinkedIn, we may collect the personal information that you make available to us on that page or account, including your social media account ID. We will comply with the privacy policies of the social media platform and we will only collect and store such personal information that we are permitted to collect by those social media platforms. With your consent, we also may share information about your activities, including what you view on our websites, with that social network’s users.
Other Information We Collect
We also may collect other information about you, your device, or your use of POGO Services in ways that we describe to you at the point of collection or otherwise with your consent. You may choose not to provide us with certain types of information, but doing so may affect your experience in using the Services.
Use of Data
POGO uses the collected data for various purposes:
- To provide and maintain POGO Services
- To notify you about changes to POGO Services
- To allow you to participate in interactive features of POGO Services when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve POGO Services
- To monitor the usage of POGO Services
- To detect, prevent, and address technical issues
- To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Additionally, POGO may share your information with:
- Third-Party Service Providers. Third party agents and vendors perform functions on our behalf, including, but not limited to, hosting, content management tools, social media integration, marketing, fundraising, analytics, billing, and customer service. These entities may have access to personal information if needed to perform their functions. If such access is required, the third parties will be obligated to maintain the privacy and security of that personal information. They are restricted from using, selling, distributing, or altering this data in any way other than to provide the requested services to POGO.
Or in the form of:
- Aggregate or Anonymous Information. We also may share other information with third parties in a manner that does not identify particular users. For instance, we may share such information to help us determine how parts of Services are used, so that we may improve our Services. We will also may share aggregate information with our partners and other third parties about how our users collective demographics or how they collectively use our Services. We also may share aggregate information with our partners about how many advertising impressions were delivered.
Additionally, business operations and functions may require the sharing of your data, for example in instances such as:
And finally, we may share your information:
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
POGO may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- For payment processing purposes
- To comply with the law
Retention of Data
POGO will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of POGO Services, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
Disclosure of Data
POGO will fight to safeguard your Personal Data to the best of our ability as permitted by law. However, in some circumstances, we may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation or court mandate
- Protect and defend the rights or property of POGO
- Prevent or investigate possible wrongdoing in connection with POGO Services
- Protect the personal safety of users of POGO Services or the public
- Protect against legal liability
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
“Do Not Track” Signals
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. POGO aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update, or to delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where POGO relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate POGO Services (“Service Providers”), to provide POGO Services on our behalf, to perform POGO Services-related services, or to assist us in analyzing how POGO Services are used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of POGO Services.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of POGO Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page:
Intellei is a Facebook application that interacts with users who engage it via our platform page on Facebook, and tracks and reports data on user engagement and activity. Intellei uses the data collected to track and monitor the use of and interaction with the POGO Facebook page to provide insights on how to better reach a given audience on Facebook. Information about Intellei can be found here:
We may provide paid products and/or services within POGO Services. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Blackbaud / Convio
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.
POGO Services does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Your California Privacy Rights
POGO does not disclose your personal information to third parties for the third parties’ direct marketing purposes unless you affirmatively agree to such disclosures.