Introduction
Tocsin Group, LLC ("Tocsin," "we," or "us") respects your privacy and is committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website tocsingroup.com, including its subdomains (our "Website"), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On this Website, including through the contact form and the Online Order Form.
- In email and other electronic messages between you and this Website.
It does not apply to information collected by:
- Us offline or through any other means, including information a client provides to us in the course of the advocacy services we perform under an Advocacy Services Order Form. The handling of that information is governed by the Advocacy Services Terms of Service.
- Any third party, including our payment processor on the pages it hosts, and any website that may link to or be accessible from the Website.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@tocsingroup.com or at the address under Contact Information below.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information:
- By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information");
- About the business you represent, such as its legal name, entity type, jurisdiction of organization, address, industry, and the federal legislative and regulatory subject matter on which it seeks advocacy (its "Issue Portfolio"); and
- About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site, in the form of the server logs and functional browser storage described below.
- From our payment processor, in the form of the payment status and account identifiers described below.
Information You Provide to Us
The information we collect on or through our Website may include:
- Contact form. Your name, company, work email address, telephone number, the reason for your inquiry, your industry, the size of your business, any bill or measure you identify, and the message you write.
- Online Order Form. The information needed to enter into an Advocacy Services Order Form: the client's legal name, entity type and jurisdiction of organization, principal business address, the name, title, and email address of the client's Designated Representative, the billing contact's name and email address, the notice email address, a telephone number, the client's disclosure of any foreign ownership or control, the Issue Portfolio, the client's industry, and the payment method selected.
- Electronic acceptance record. When an Order Form is accepted electronically, we record the typed name and title of the person accepting it, the consents given, the date and time of acceptance, the version of the Terms of Service accepted, the Internet Protocol (IP) address and browser identifier of the device used, and a copy of the Order Form and Terms of Service as accepted. We keep this record as evidence of the Agreement. When Tocsin accepts an Order Form, the executed agreement is emailed to the client as a PDF and a copy of that PDF is kept with the order record.
- Correspondence. Records and copies of your correspondence (including email addresses), if you contact us.
Payment Information
Fees are collected by our payment processor, currently Stripe, Inc. and its affiliates ("Stripe"). When you pay, you enter your card or bank account details on pages that Stripe hosts and controls. Stripe collects that information directly. We do not receive or store your complete card number or bank account number. We receive from Stripe the status of each payment, the type and last digits of the payment method, the billing name and address you enter, and the customer and subscription identifiers Stripe assigns. Stripe's collection and use of your information is governed by Stripe's privacy policy, currently available at https://stripe.com/privacy. Stripe may also use your information to prevent fraud and to comply with its own legal obligations.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, the following information may be collected automatically:
- Server logs. Our Website is hosted by Netlify, Inc. ("Netlify"). Netlify's servers record the IP address, browser type, operating system, pages requested, referring page, and date and time of each request. We use these logs to operate and secure the Website and to measure aggregate traffic.
- Visit log. When you open a page, our Website records the time, the page (never its query string), the referring site, any campaign tag in the link and whether the link came from a Google Ads click (not the click identifier), your approximate location (country, state and city, which Netlify derives from your IP address), your device type, browser and operating system, on the order page the plan and industry link you used, and a visitor code computed from your IP address and browser with a key that changes daily and is deleted two days later. We do not store your IP address or set a cookie. We use this log to count visits and to see which pages each visitor opened that day, including visitors who arrive from our ads, so we can operate, secure and improve the Website.
- Form and order storage. Contact form submissions and order records are stored on infrastructure provided by Netlify.
- Functional browser storage. The order flow uses your browser's session storage to carry the Order Form you are completing from one page to the next. That information stays on your device, is not sent to us until you submit the form, and is cleared when you close the browser tab. We do not use advertising cookies, third-party analytics scripts, web beacons, or cross-site tracking. If we introduce a cookie for a functional purpose, we will update this policy to describe it.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To respond to inquiries submitted through the contact form or by email.
- To review, confirm, and perform an Advocacy Services Order Form, including to confirm acceptance in writing, to deliver reports and briefings, and to communicate with the Designated Representative and the notice email address.
- To bill and collect Fees through the payment processor, to issue receipts, and to notify you of failed payments and renewals.
- To prepare and file the registrations and reports required of Tocsin under the Lobbying Disclosure Act, the Foreign Agents Registration Act, and other applicable law. Filings under the Lobbying Disclosure Act are public records. They disclose, among other things, a client's name and address, the general and specific issues on which Tocsin advocates, and Tocsin's income from that client (Terms of Service, Section 5.1).
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To operate, secure, and improve the Website.
- To notify you about changes to our Website or to the services we offer.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We do not sell or rent personal information. We do not use personal information for targeted advertising.
Disclosure of Your Information
We may disclose aggregated information about our users that does not identify any individual without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
- To service providers we use to support our business, including Stripe (payment processing and billing), Netlify (website hosting, form submissions, and data storage), and Microsoft 365, Tocsin's email provider, through which transactional email (receipts, the executed agreement, notices, and reports) is sent. If Tocsin replaces its email provider, the deployment runbook names the replacement. These providers are permitted to use the information only to provide their services to us.
- To Covered Officials, coalition partners, and other Tocsin clients in the course of advocacy, to the extent the Advocacy Services Terms of Service permit. Unless a client opts out on its Order Form, Tocsin may identify the client by name as a Tocsin client and as a supporter of positions within its Issue Portfolio (Terms of Service, Section 9.2). A client's Confidential Information is shared with other clients participating in Coordinated Advocacy only as Section 9.1 of the Terms of Service allows.
- In public filings with the Secretary of the Senate and the Clerk of the House of Representatives under the Lobbying Disclosure Act, and in any other filing that applicable law requires of Tocsin (Terms of Service, Section 5.1).
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Tocsin's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Tocsin about our Website users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Website Terms of Use, the Advocacy Services Terms of Service, and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Tocsin, our clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
Data Retention
We keep contact form submissions for as long as needed to respond to the inquiry and to maintain a record of our correspondence. We keep order records, the electronic acceptance record, and the copy of the Agreement as accepted for the term of the Agreement and for as long afterward as is needed to document the Agreement, to resolve any dispute, and to satisfy legal, accounting, and lobbying-disclosure recordkeeping requirements. Stripe retains payment records under its own policy. Netlify retains server logs under its own policy. We keep the visit log for 35 days; after that we keep only daily totals that do not identify any visitor. When a retention period ends, we delete or de-identify the information.
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The Website is served over encrypted connections. Order records are stored with access limited to the persons who need it to perform the Services and to administer billing. Payment details are handled by Stripe and never reach our systems in full.
The safety and security of your information also depends on you. The links in the emails we send a client, which open its signed Order Form, its executed Agreement and its billing portal, are private to that client. Treat those links as confidential and share them only with persons authorized to act for the client.
The transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. You have the following controls over your information:
- Public identification. Under the Terms of Service, Tocsin may identify a client by name as a Tocsin client and as a supporter of positions within its Issue Portfolio in advocacy materials, correspondence with covered officials, coalition communications and Tocsin's marketing materials. When an agreement ends, Tocsin stops naming the client in new materials and removes the client's name from marketing materials it controls within thirty days.
- Payment information. You may update your payment method and billing details through the billing portal provided by Stripe, reachable from the Manage billing page of the Website.
- Browser storage. You may clear your browser's session storage at any time. Doing so before you submit the Online Order Form discards the form.
- Correcting your information. A client may update its Designated Representative, billing contact, notice email, and other contact information by written notice to support@tocsingroup.com (Terms of Service, Section 14.4).
We do not serve interest-based advertising and do not share personal information with advertising networks.
State Privacy Rights
The privacy laws of some states give their residents rights over personal information. Depending on the state, those rights may include the right to know what personal information a business has collected, the right to access it, the right to correct it, the right to delete it, and the right not to be discriminated against for exercising those rights. Many of those laws apply only to businesses above certain size or revenue thresholds, or do not apply to information collected from a person acting in a business capacity. Whether or not a particular law applies to Tocsin, you may send a request to access, correct, or delete the personal information we hold about you to support@tocsingroup.com with the subject line "Privacy request." We will verify the request, respond within the time the applicable law allows, and tell you if we cannot honor it, for example because we must keep the information to document an Agreement or to satisfy a legal obligation. We do not sell personal information and do not share it for targeted advertising, so there is no sale or sharing to opt out of.
Do Not Track Signals
Some browsers transmit "Do Not Track" or Global Privacy Control signals to the websites you visit. Because we do not track users across third-party websites and do not sell or share personal information for targeted advertising, our practices do not change in response to these signals.
Links to Other Websites
The Website links to third-party websites, including Stripe's checkout and billing pages, congress.gov, and other public legislative sources. Those websites have their own privacy policies. We are not responsible for their practices.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify clients by email at the notice email address on file and other users through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, or to make a privacy request, contact us at:
Tocsin Group, LLC
20 F Street NW, 7th Floor
Washington, DC 20001
support@tocsingroup.com (privacy questions and requests)
contact@tocsingroup.com (general inquiries)