1. PERSONAL DATA WE COLLECT

The information we collect varies, depending on the way you use our Site Features.  For all data not excluded above, we process personal data in the ways described below.  

We use the term “personal data” (aka “personal information”) in this Privacy Policy to mean any information that is linked or reasonably linkable to an identified or identifiable individual; it does not include de-identified data, publicly available information, or employment or job applicant information. As described below, we collect personal data that (a) you give to us; (b) we receive from others; (c) we collect automatically; and, in limited instances, (d) we infer.

      a. Personal Data You Give to Us

This is personal data that you share with us – directly and voluntarily – through our Site Features, including the following categories of personal data: 

• Contact information, like your first and last name, email address, mailing address, and phone number. 
• Legal information, including details about your bail (e.g., amount and/or type), legal or criminal history, or other information you provide on our Site for a referral for bail assistance.
• Donation information, like first and last name, payment information, billing address, profession, or donation history. Please note that we use service providers/processors to process donations made through the Site. 
• Inquiry and communications information, like information provided in custom messages sent through web forms on our Site, as well as your preferred method of communication. 
• Demographic information, like your age, ethnicity/race*, or preferred language. Please note that ethnicity/race information is considered “sensitive data.” Where we ask for ethnicity/race information, it is an optional field and you are not required to submit this information to make a referral or support our work. 
• Interaction information, like your donation and purchase history and organization support.
• Other information. For example, if you fill out any forms or participate in our events, surveys, competitions (e.g., sweepstakes), or other promotional events, you may be asked to provide your contact information (as defined above), your demographic information (as defined above), and any other information requested on the form, at sign-up, or as part of the relevant promotion entry. On occasion, you may also provide your shipping and billing information for the purpose of claiming a prize. 

      b. Personal Data We Receive from Others

We may receive personal data about you from third-party sources, such as service providers/processors and social media platforms. Through your interactions with these third parties, we may receive the following: 

• • Contact information, as defined above.  
  • Demographic information, as defined above.  
  • Financial information, like estimated household income, business holdings, net worth, or other assets that may be inferred or derived from publicly available sources for engaging current and identifying prospective donors.  
  • Social media information. We may receive information about you through social media  – for example, when you like our Facebook page, follow us on X or Instagram, engage with similar organizations on LinkedIn, or watch our content on Vimeo or YouTube. The data we receive is dependent upon your privacy settings with such social media platforms and subject to each platform’s respective privacy policies.
• Other publicly available information.

      c. Personal Data We Collect Automatically

As you interact with our Site, we and/or our authorized service providers/processors may use automatic data collecting technologies to collect certain personal data about your equipment, browsing actions, and patterns, including:

• Information about the computer, smartphone, or other device you use, including your IP address, browser type, internet service provider, device type/model/manufacturer, and date and time stamp.

• Information about how you access and use our Site, including the content you click on or view, referring and/or exit page URLs, the amount of time you spend on our Site, and other browsing behavior and actions you take on the Site. 

• Information about your location, including your approximate geographic location that we or authorized third parties may derive from your IP address. We do not collect precise geolocation data. 
• Analytics information. For example, analytics data and tools like Google Analytics and Hotjar help us measure traffic and usage trends for the Site and understand more about our users. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser, and you may be able to disallow Hotjar from collecting personal data through your browser. You can learn more about Google’s practices here and Hotjar’s practices here. 

The technologies we use for automatic data collection may include:  

• Cookies. A cookie is a piece of information that a web server may place on your device when you visit a website. A cookie will give us information about how you use the Site (e.g., the pages you view, the links you click, how frequently you access the Site, and other actions you take on the Site). You should refer to instructions in your browser and device to delete and disable cookies, or for our Site specifically through the “Cookie Preferences” link in the Site footer. 

• Web Beacons. Pages of our Site and our marketing emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to, for example, count users who have visited those pages or opened an email, and gather other related statistics. 
• Session Recorder. We use the service provider/processor Hotjar for session recording, which monitors and records all of a user’s behavior on our Site, including mouse movements, clicks, scrolling, and anything typed into a form.  

More information about tracking technologies and opt-out options is available here, on Hotjar’s website, and in section 5 (“Your Privacy Choice and Rights”) of this Policy.

      d. Personal Data We Infer

We may use the data that we have collected – directly from you, received from others, and automatically – to combine, compile, and infer new information about you. We and our service providers/processors may infer the following categories of data, all of which are defined above: contact information, demographic information, financial information, interaction information, and inquiry and communications information. Please note that some state privacy laws afford residents the right to opt out of profiling or automated decision-making with legal or similarly significant impacts; we do not conduct these activities.

2. HOW WE USE PERSONAL DATA

We use the personal data collected about you for the following purposes: 

• Fundraising

As a donor-supported nonprofit organization, we rely on financial support to continue our mission and operations. To that end, we may use your personal data to process and solicit donations.

• Outreach

We may use personal data to communicate with you about The Bail Project through a number of communications channels, including marketing emails. 

• Targeted Advertising

We use personal data to deliver targeted advertising to individuals who are likely to support The Bail Project. Note that we do not use personal data for targeted advertising when we obtain it from individuals contacting us via our referral form for bail assistance on behalf of themselves or others. See section 3 (“Targeted Advertising”) for more information.

• Screening and Intake for Our Bail Assistance and Community Release with Support Services

We use personal data to respond to requests submitted through our Site referral form for bail assistance and community release with support services from The Bail Project.  

• Referrals to Partner Bail Funds

In the limited circumstance that you are able to submit a request through the Site referral form for help paying bail in a jurisdiction we do not serve, we may provide the personal data collected to a partner bail fund for the purpose of referring you for their services. We have binding, written agreements with these partner bail funds that require them to process personal data received from us in compliance with applicable laws. 

• Digital Services Optimization and Secure Operations

We may use your personal data to provide you with a secure and optimized experience when engaging with our Site Features. To that end, we may use your data in user experience testing, website performance assessment, and fraud detection, as well as for Site security. 

• Analytics

We use third-party analytics tools to collect information about the use of the Site Features. These service providers/processors collect information, such as how often users visit the Site, what other websites users visit, and what other websites users viewed prior to coming to the Site. We use the data we receive from service providers/processors to improve the performance and features available through our Site and to personalize your experience. 

• When Required by Law, to Prevent Fraud, and Protect Our or Others’ Rights

As a nonprofit organization, we are required to submit donation reports to governmental entities and to comply with other legal obligations. We may use your personal data to meet these legal requirements and to prevent fraud or protect our or others’ rights.

• De-Identification

We may de-identify personal data (so that you can no longer be identified) to proactively minimize the data in our possession when the purpose for such personal data has ended. To the extent feasible, we may also de-identify data to remove it from records that otherwise must be retained for legal purposes when you request for us to delete your personal data. We may use de-identified data for research purposes, to show the impact of our organization, and for advocacy, fundraising, and other mission-related purposes. When we de-identify data permanently, we will use it only in its de-identified form and will not attempt to re-identify the data.  Once data is de-identified, it is no longer considered personal data subject to this Privacy Policy.  

• Advocacy and Organizing

We may use your personal data to bolster our advocacy and organizing efforts in support of our mission.  This includes facilitating educational or advocacy campaigns, delivering petitions and action messages to you, organizing and hosting related events, and mobilizing volunteers and supporters around our mission. 

• Other Uses

We may use your personal data to operate, maintain, and enhance The Bail Project and/or with your consent, as permitted by law, as we may notify you, or as otherwise described to you in this Policy or at the point of collection.

3. TARGETED ADVERTISING

We may display targeted ads to you on third-party platforms, websites, and social media platforms that are not operated by The Bail Project, such as Facebook, Instagram, Reddit and X. Targeted ads help us reach people who are most likely to support our organization and/or have an interest in our mission. For this reason, we may share your personal data with advertising partners to serve targeted ads to specific individuals, including you, or to display ads to individuals who are similar to those who have engaged with us in the past (i.e., “look-alikes”).

When we share your data with an advertising partner, it is first transformed irreversibly into randomized code (i.e., “hashed”) and can only be used to match you to data the advertising partner already possesses to serve the ad. We only share your data with advertising partners that promise to hold the transmitted data securely. 

If you do not wish to have your personal data shared with third-party advertisers for targeted advertising, please refer to section 5 (“Your Privacy Choices”) and/or contact us as described in section 12 (“How to Contact Us”). 

Specifically, we may engage in the following: 

• Social Media Widgets

Our Site Features may include social media features, such as the Facebook “like” button, Instagram, X, and/or other widgets. These social media platforms may recognize you and collect data about your visit to our Site and use of Site Features. They may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those third parties. 

• Social Media Targeted Advertising 

We may display targeted ads to you through Facebook, LinkedIn, X, Instagram, Reddit and other social media platforms. These platforms have interest-based advertising programs that allow us to direct ads to users who have shown interest in our organization while those users are on the social media platform or to groups of other users who share similar traits. 

Our Site uses the Meta Pixel to enable us to direct targeted ads to you or to a custom audience on the platform. Note that these ads are governed by Facebook’s privacy policies. You may learn more about Facebook privacy settings and how to change your preferences here. We may also work with our advertising partners, such as X and Google, for targeted ads. These ads are governed by the respective company’s privacy policies, and you should review those policies for details about how to change your preferences. You can opt out of targeted ads. Please see section 5 (“Your Privacy Choice and Rights”) for details.

4. WHOM WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with third parties, including those listed in this section. We will notify you if we share personal data with third parties not described here.

• Partner Bail Funds

As noted above, in the limited circumstance that you are able to submit a request through the Site referral form for help paying bail in a jurisdiction we do not serve, we may provide the personal data collected to a partner bail fund for the purpose of referring you for their services. We have binding, written agreements with these partner bail funds that require them to process personal data received from us in compliance with applicable laws. 

• Service Providers/Processors

We work with a variety of service providers/processors who help us process your personal data. These service providers may facilitate the operation of our Site Features; support our fundraising, marketing, communications, and advocacy programs; or provide tax, accounting, web hosting, recruitment, analytics, security, and payment processing services. We have binding, written agreements with these service providers that require them to process personal data received from us in compliance with applicable laws. 

• Advertising Partners

We may share personal data with third-party advertising partners to display targeted ads to you on third-party platforms that we do not own or operate, third-party websites, and social media platforms, such as Facebook and Instagram. These partners may collect data directly from a browser or device when an individual visits our Site through cookies or other data collection technologies. This information is used to provide advertising-related services, such as reporting, analytics, and market research. We target our ads to effectively and efficiently reach people who are most likely to take action, including to donate to or otherwise support our organization. 

• Business Partners

We may take part in or be involved with a business transaction, such as a merger, sale of the organization’s assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our organization by another organization or third party, or in the event of a bankruptcy or related or similar proceedings. We may disclose personal data to a business partner during the negotiation of or in connection with such a transaction, but to the extent permitted by applicable law, we will only disclose such data upon the third party agreeing to the same or stronger protections of your personal data than are set forth in this Policy.  

• Third Parties When Legally Required

We may share personal data with third parties when required by law or subpoena, or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement or regulatory authorities; (ii) to enforce our Terms of Use or to protect the security or integrity of our Site; and/or (iii) to exercise or protect the rights, property, or personal safety of The Bail Project, our clients, and employees.

• With Your Consent

We may disclose personal data about you to certain other third parties or publicly with your consent. For example, with an individual’s consent, we may distribute their testimonial through our Site, on social media platforms, or through marketing emails.

5. YOUR PRIVACY CHOICES AND RIGHTS

Depending on where you reside, and subject to certain legal limits, you may or may not have some or all of the following rights in relation to the personal data we possess about you.  Please note that some privacy laws afford individuals the right to opt out of profiling or automated decision-making with legal or similarly significant impacts; we do not conduct activities that have such impacts. Your exercise of any of these rights will not result in any discriminatory treatment to you.   

• Know. You may have the right to be informed about our collection, use and disclosure of your personal data.  We accomplish such transparency through the publication and maintenance of this Privacy Policy.  
• Access. You may have the right to access personal data that we possess about you (subject to the rights of others).  
• Correction. If any personal data we have collected about you is inaccurate, incomplete or out of date, you may have the right to have that data corrected or updated. 
• Deletion. You may have the right to request deletion of your personal data in certain situations.  
• Portability. Subject to the rights of others, you may have the right to request a copy of your personal data (if available) and transfer it in a commonly used electronic form (if feasible). 
• Opt out. You may have the right to opt out of certain processing activities, including, for example, the use of your personal data for targeted advertising purposes.
• Withdraw consent. If we are processing your personal data based on your consent, you may withdraw your consent at any time.  If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

      a. Opting Out

You have the choice to opt out of:

• Promotional email communications. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. We make every effort to promptly process all unsubscribe requests. Note that you may not opt out of Site-related communications (e.g., transactional communications, changes/updates to services or the terms that govern them, technical and security notices).  
• Targeted advertising. You can opt out of targeted advertising by following the instructions in subsection (c) below (“Submitting a Privacy Choices Request”). Additionally, Global Privacy Control (“GPC”) is a browser setting that allows you to notify websites you visit about your privacy preferences. You may use the GPC to communicate your privacy preferences regarding targeted advertising. We honor website visitors’ GPC signals. We will respond to your request without undue delay and in compliance with applicable legal requirements. 

      b. Disabling Cookies and Tracking Technologies

You can opt out of targeted ads through our cookie consent pop-up that should appear when you first visit our Site (click the “Manage Preferences” button to review your options) or through the “Cookie Preferences” link in the Site footer. As noted above, you can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Note that disabling cookies on your browser, including strictly necessary cookies, may impact the operability of some Site Features. 

      c. Submitting a Privacy Choices Request

You may submit a privacy choices request to us, or authorize another party to do so on your behalf, as follows: 

• Contact us. You may submit a request to us, or you may authorize another party to do so on your behalf, using the Your Privacy Choices form.
• Identity verification. When you or your authorized agent submit a request, we will need to confirm your identity. We may contact you for additional information to verify your identity. 
• Appeals. If we deny your request, you may appeal our decision within a reasonable period by contacting us through the Your Privacy Choices form. We will review and provide a written explanation for our response in compliance with applicable legal requirements.  

      d. California Privacy Rights

California Civil Code Section § 1798.83 (“Shine the Light” Law) permits California residents to opt out of disclosure of personal information to third parties for marketing purposes at any time. Once a year, California residents are entitled under the Shine the Light Law to request and obtain certain information, free of charge, regarding our disclosure, if any, of personally identifiable information to third parties for their direct marketing purposes in the preceding calendar year (e.g., requests made in 2023 will receive information about 2022 sharing activities). Currently, we do not share personally identifiable information with third parties for their direct marketing purposes.  Please also understand that The Bail Project is not subject to the California Consumer Privacy Act (CCPA) or to the California Consumer Privacy Rights Act (CPRA) as The Bail Project is a nonprofit organization. As stated earlier, The Bail Project does not sell your personal information and we strive to provide clear notices of our privacy practices at the time of collection and honor your privacy requests when feasible.

6. DATA RETENTION

We will retain your personal data consistent with our legitimate interests and to comply with any applicable laws, regulations, legal requirements including investigations, legal hold demands or lawsuits, our internal record retention policies and schedules and/or our contractual requirements.

7. SECURITY

We will use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of your personal data. Importantly, no security system is impenetrable and we cannot guarantee the security of your personal data. If any personal data under our control is compromised as a result of a security incident, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose data has been compromised and take other steps in accordance with any applicable laws and regulations or where we deem appropriate.

You are responsible for notifying us immediately of any known or suspected unauthorized uses of your personal data through the Site Features and agree to cooperate with us in any investigation necessary related to a security incident.  

8. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any personal data from anyone under the age of 18 or knowingly allow such persons to register as users of the Site Features. If we learn that we have collected personal data from a child under age 18, we will delete that information as quickly as possible. If you believe that we have any personal data from a child under 18, please contact us via our referral form.

9. U.S. NONPROFIT ORGANIZATION

We are a United States (“U.S.”) nonprofit organization and process the personal data we collect and receive in the U.S. only.  If you are accessing Site Features from outside of the U.S., please be aware that information collected will be transferred to, processed, stored, and used in the U.S. Please note that the data protection laws in the U.S. may be different than the laws in your region. Your use of our Site Features (including providing us with any of your personal data) therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. as set out in this Privacy Policy.

10. LINKS TO OTHER WEBSITES AND SERVICES

You are responsible for deciding if you want to access or use third-party apps or websites that link from our Site. If you allow a third-party app or website to authenticate you or connect with your account on a third-party platform, that app or website can access information related to you. Third-party apps and websites have their own legal terms and privacy policies, and by using them and agreeing to their terms you may be giving others permission to use your information in ways we do not pursuant to this Policy. We are not responsible or liable for these other apps and websites (unless required by applicable laws) – you use these at your own risk.

11. CHANGES TO OUR PRIVACY POLICY

From time to time, we may make changes to our Privacy Policy. We will notify you of any material changes to this Policy where required by law. We will also post an updated Policy on our Site. Please check our Site periodically for updates. Your continued use of our Site Features after a posted update to the Privacy Policy constitutes your consent to the updated Privacy Policy terms.

12. HOW TO CONTACT US

Please contact us with any questions regarding our Privacy Policy here or at:

The Bail Project
P.O. Box 750
Venice, CA 90294
(323) 366-0799