Document Owner: Information Security Committee
Date Approved: August 2023
Date Last Reviewed: August 2023
Purpose & Scope
At the core of these regulations is the desire to protect the privacy of individuals or consumers, often described as data subjects. In accordance with these various statues and regulations, with the intent of ensuring transparency, Allegiance Group, LLC does recognize these various data subject rights that span the various privacy regulations.
The right to correct inaccuracies
The right to restrict processing
The right of data portability
The right to know how data is being shared with a 3rd party
The right to know the purpose for which information has been collected
The right to request the type and categories of data that has been collected
The right to be forgotten or deleted.
The right to opt out
The right to request information & the right to have access to information
The right to access the data subject's own data and confirm if data is being processed
These rights are confirmed by Allegiance Group, LLC as long as these rights do not interfere with the company’s ability to provide goods or services as a required function of their business purpose and/or as requested by the data subject. These rights also may not interfere with the ability of Allegiance Group, LLC to maintain the records necessary to meet the privacy requirements.
State or other regulatory requirements for Opt-In will be handled via contracts between Allegiance Group, LLC and their clients, as Allegiance Group, LLC does not work directly with consumers, constituents, or data subjects. By the nature of the contractual agreements to work together, Allegiance Group, LLC customers understand that they are acknowledging opt-in regarding data sharing only for the business purpose documented and outlined in the relationship documents. Regarding the client customers of Allegiance Group, LLC, their own data subjects should be informed within Allegiance Group, LLC’s customers own agreements with their constituents, that they (our customers data subjects) Consent by Proxy for their data to be utilized by third parties of our customer, only for the intended business purpose they seek from their relationship with Allegiance Group, LLC.
How we collect and use information
We may collect the following types of information that is required to fulfill our business purpose:
* Information you provide (not including your Constituent or Giving data). When you sign up for some of our products, we ask you for personal information. We may combine the information you submit under your account with information from other Allegiance Group, LLC services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
* Constituent and Giving Data when you connect constituent data (your donor’s name, email address and/or physical address and any other associated constituent data) and giving data (transaction ID, amount, date of transaction and any other associated giving data) either via a third-party integration or uploading directly, we will not share that data with any third-parties or Allegiance Group, LLC clients. This data is not used or sold even in an aggregated, anonymized form to any third parties or Allegiance Group, LLC clients. You are the sole owner of your constituent and giving data and you can delete this data from our system at any time, and all data subject rights will pertain to your constituent data.
* Log information. When you access Allegiance Group, LLC services via a browser, application, or other client, our servers automatically record certain information. These server logs may include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account. Log information is also critical for support issues that may be brought to Allegiance Group, LLC regarding our Apps or services.
* User communications. When you send email or other communications to Allegiance Group, LLC, we may retain those communications to process your inquiries, respond to your requests and improve our services. When you send and receive SMS messages to or from one of our services that provides SMS functionality, we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction. We may use your email address to communicate with you about our services.
* Location data. Allegiance Group, LLC offers location-enabled services, sometimes part of another application. If you use those services, Allegiance Group, LLC may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location (such as a cell ID) only for the intended business purpose of the relationship.
In addition to the above, we may use the information we collect to:
* Provide, maintain, protect, and improve our services and develop new services.
* Protect the rights or property of Allegiance Group, LLC or our users.
If we use this information differently than the purpose for which it was collected, we will ask for your consent prior to such use.
How we share your personal information
Allegiance Group, LLC may share your personal information (Allegiance Group, LLC App and Service user) with other entities with the sole intent to improve the experience of the product and the service’s business intent. These entities may use your personal information to help fulfill your requests in connection with the services and to help communicate with you about different resources offered as part of the services. Also, our parent, subsidiary and affiliate companies, or entities to which any of our assets, products, sites or operations may be transferred, will be able to use your personal information for the intended business purpose of which there is a contractual agreement with Allegiance Group, LLC.
We may also release our clients personal information (not the personal information of our clients constituents) to third parties if we believe such release is necessary (i) to comply with the law (e.g., a legal process or a statutory authorization), (ii) to apply or enforce our user agreements, (iii) to protect our rights or property, (iv) as part of a corporate reorganization, consolidation, merger, or sale of substantially all of the assets of Allegiance Group, LLC, or (v) if we reasonably believe that a danger to any person requires disclosure of such personal information.
Beyond the improvement of the experience required for our core business purpose, or for required legal and business transaction purposes, Allegiance Group, LLC does not share the provided constituent or giving data with any third parties or Allegiance Group, LLC clients.
Links to other sites:
Please note that, while using the services, you could be directed to other sites that are developed and administered by people or companies not affiliated with or controlled by Allegiance Group, LLC. These other sites may place their own cookies on your computer, collect data or solicit personal information.
* We have appointed a DPO (Data Protection Officer) whose job is to keep you and your customers’ data safe, answer any questions you have about your data and maintain compliance with all applicable laws.
* We are updating our Account Settings so our users can easily manage or opt-out of communication from Allegiance Fundraising Group LLC.
* Allegiance Group, LLC has a managed service relationship with a partner that ensures our cyber security and compliance needs are met including weekly meetings, regular policy review, technical testing of cyber security and regulatory controls and user awareness training on the handling of sensitive data.