Privacy Notice for ADT Employees PAC Website

Last Updated: October 14, 2013

This ADT Employees PAC website (the “Site”) is operated by Democracy Data & Communications, LLC (“DDC Advocacy”) on behalf of ADT LLC d/b/a ADT Security Services, Inc. and its affiliated entities (“ADT,” “we,” “us,” or “our”). We have designed the Site to help coordinate and facilitate contributions to the ADT Employees Political Action Committee (the “PAC”) by authorized ADT employees and service providers.

Privacy is important to ADT and we strive to keep you informed about how we collect, use, and share your information. The purpose of this Privacy Notice is to explain our privacy practices with respect to information you provide to us on or through Site. It does not apply to “offline” interactions or activities that are unrelated to the Site. By accessing the Site, you agree to the terms and conditions set forth below. You should also be aware that use of ADT’s computer and data communication systems is governed by our Acceptable Use Policy.

Please note that contributing to the PAC is entirely voluntary. All contributions are subject to the prohibitions, limitations, and reporting requirements of the Federal Election Campaign Act and other applicable laws. Any contributions you choose to make may be used for political purposes, including supporting political groups or candidates, and are not tax deductible. You have the right to refuse to contribute without reprisal. ADT will not consider your use of the Site, or your decision to contribute or not contribute to the PAC, in any ADT employment decisions. Only eligible persons may contribute to the PAC, and contributions from foreign nationals are prohibited.

1. How We Collect and Use Your Information

We collect two primary types of information through the Site: “Personal Information” and “Other Information”. Personal Information refers to information that can reasonably be used to directly contact you or identify you as a particular individual (e.g., your name, postal address, e-mail address, telephone number, etc.). By contrast, Other Information means any information that does not reveal your specific identity or does not directly relate to you as an individual (e.g., the type of Internet browser you use to access the Site).


Personal Information

ADT generally only collects Personal Information through the Site when you voluntarily provide it to us, such as when you complete and submit our online forms. This means that you may be able to interact with parts of the Site without submitting any Personal Information to us. Please note, however, that if you do not provide us with the information we request, you may be unable to access or use certain Site functions. For example, if you would like to contribute to the PAC, we will ask you to provide us with certain types of Personal Information (e.g., name, address, telephone number, payment details, etc.) so that we can confirm it. Although you may choose to not provide us with the requested information, this would likely prevent us from completing the transaction you initiated.

We ask that you not disclose any sensitive Personal Information (e.g., information related to your racial or ethnic origin, personal health, trade union membership, etc.) to us on or through the Site.

The primary reason we collect Personal Information is to facilitate donations you choose to make to the PAC. Under certain situations, we and our third-party service providers may also use Personal Information for other purposes, such as:

  • operating, managing, and improving the Site; ?
  • responding to your inquiries or requests; ?
  • complying with applicable law and legal process, potentially including laws outside your country of residence; ?
  • responding to requests from public and government authorities, potentially including such authorities outside your country of residence; ?
  • ensuring compliance with our policies, rules, and procedures;  ?
  • protecting our operations and those of any of our affiliates; and ?
  • protecting our rights, privacy, safety, and property, and that of our affiliates, you, and others.

For example, U.S. federal law requires the PAC Treasurer to use best efforts to collect and report the name, address, occupation, and employer for each individual whose contribution to the PAC exceeds $200 in a calendar year. If your donations exceed this threshold in a given calendar year, we may be required to disclose Personal Information to government officials in accordance with our legal obligations.

ADT may also use your Personal Information for other purposes when you provide us with prior consent to use your information in such a manner.

Other Information

We and our third-party service providers may also collect Other Information through the Site, including automatically with tools such as “cookies” or similar tracking technologies. Examples of the various ways we may obtain Other Information about you through the Site include:

  • Through your Internet browser: Certain system-related information is collected by most Internet browsers. We may collect this information in order to, among other things, monitor, operate, and improve the Site. ?
  • Using tracking technologies: We may use cookies and similar tracking technologies to collect Other Information from you automatically when you visit the Site. Cookies are small pieces of data that are based on your Internet activity and stored on the hard drive of your computer by your Internet browser when you visit a website. Through the use of cookies and similar tracking technologies, we may collect information about your interactions with the Site (e.g., the particular links that you click). This information helps us to identify user preferences, analyze usage patterns, improve security, and otherwise operate or improve Site.

If you do not wish to accept cookies, there is a simple procedure in most Internet browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. Please note that if you do not accept cookies on the Site, you may experience some inconvenience and certain Site features may not function properly. You should also be aware that changing your preferences with respect to cookies may not affect the functionality of other tracking technologies.

  • Reviewing our server logs: Your “IP Address” is a number that is automatically assigned by your Internet Service Provider (ISP) to the computer or device that you are using to access the Site. An IP Address is identified and logged automatically in our server logs whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. We may use this information in order to, among other things, monitor, manage, operate, and improve the Site. ?
  • From you: You may be provided with an opportunity to submit information to the Site that does not personally identify you or any other user of the Site. Unless it is combined with Personal Information, we will treat this information as Other Information for the purposes of this Privacy Notice. ?
  • By aggregating or de-identifying information: Occasionally, ADT will take steps to aggregate, de-identify, or otherwise “anonymize” Personal Information so that it can no longer reasonably be used to directly contact you or identify you as a particular individual. For example, we may combine Personal Information about you with Personal Information about many other PAC donors to determine the total number of ADT employees from a given state who contributed to the PAC over the past year. Because this information is no longer personally identifiable, it is treated as Other Information for the purposes of this Privacy Notice.

In some instances, we may combine Other Information with Personal Information. In such cases, the combined information will be treated by us as Personal Information as long as it is combined. Please note that we may use and disclose Other Information in any manner not otherwise prohibited by this Privacy Notice or applicable law, without notice or compensation to you.

 

2. Third Parties and Third-Party Sites

The Site may contain links to third-party websites. Please note that the information practices of any such third-party websites are not covered by this Privacy Notice. ADT cannot control the treatment of your information by these third parties, and their privacy practices likely differ from those described in this Privacy Notice. We strongly encourage you to review the privacy practices of any third parties prior to disclosing any Personal Information to them. The inclusion of a link on the Site does not imply endorsement of the linked site by ADT.

 

3. Security

Information collected by or through the Site is submitted to us and is hosted and stored by us (or by our service providers) in a database on servers situated in the U.S. and/or internationally. By providing us with information through the Site, you consent to the processing of such information in any and all such locations.

We maintain reasonable legal, organizational, and technical safeguards to protect Personal Information under our control. ADT has also taken steps to require its service providers to protect the confidentiality and security of Personal Information, and to ensure that Personal Information is processed only for the provision of the services to ADT and in compliance with applicable law.

It is your responsibility to maintain the confidentiality of your username and password. You are responsible for all uses of your password, whether or not such use has been authorized by you. If you become aware of any unauthorized use of your account on the Site, please immediately contact the Office of Government and Regulatory Affairs at (561) 226-3434 or GovernmentAffairs@ADT.com or the ADT Ethics Office (877) 871-5625 or ethicsline@adt.com.

Despite our efforts to protect your information, the transmission of data over the internet inherently requires the use of systems under the control of third parties. As a result, we are unable to guarantee that your interaction with the Site is 100% secure under all circumstances. If you have reason to believe unauthorized individuals have accessed or acquired information from the Site, please immediately contact the Office of Government and Regulatory Affairs at (561) 226-3434 or GovernmentAffairs@ADT.com or the ADT Ethics Office (877) 871-5625 or ethicsline@adt.com.


4. Access and Correction Requests

If you would like to review, correct, or update Personal Information about you that has been previously submitted on the Site, please contact the Office of Government and Regulatory Affairs at (561) 226-3434.

 

5. Transfer and Joint Use of Personal Information

From time to time, ADT may need to make Personal Information available to other parties such as legal and regulatory authorities; accountants, auditors, lawyers and other outside professional advisors; and to companies that provide products and services to ADT (e.g., payroll, pension scheme, and benefits providers; human resources services, performance management, IT systems suppliers and support; third parties assisting with equity compensation programs; or other outsourcing providers). Some of these services will be provided from countries outside of your home jurisdiction, including the United States.

The PAC may be required under local, state, or federal law to disclose its contributors to the applicable local, state, or federal agency that oversees campaign finance in that jurisdiction. Where required by law, ADT will disclose contributor information that may include the contributor's name, address, occupation, and amounts and dates of contributions to the PAC. Specifically, the Federal Election Commission ("FEC") requires the PAC to disclose the name, address, occupation, amount and date of every contribution made to the PAC. The FEC also requires all contributions over $200 in the aggregate in a calendar year to be reported in an itemized manner that is publicly available on the ADT PAC reports at www.fec.gov. State and local disclosure laws vary by jurisdiction.

 

6. Changes to the Privacy Notice

We may, in our sole discretion, make changes to this Privacy Notice from time to time in order to accommodate new technologies, industry practices, regulatory requirements, or for other purposes. The most recent version of the Privacy Notice will always be posted on the Site. If we do make any changes, we will also update the “Last Updated” field at the top of the Privacy Notice. We encourage you to review the Privacy Notice periodically to ensure that you understand our privacy practices on the Site.

Any changes to the Privacy Notice will become effective when the revised Privacy Notice is posted on the Site. By continuing to use the Site following such changes, you are agreeing to the terms of the revised Privacy Notice.