Last Updated: [February 20, 2025]
Sutton & Smart LLC (“we”, “us”, or “our”) is a political consulting firm committed to protecting your privacy. This Privacy Policy describes how we collect, use, share, and safeguard personal information in the course of our political consulting services and through our website or other interactions. It covers data from voters, donors, campaign supporters, and website users. By engaging with our services or providing information to us, you agree to the practices described in this Policy. We strive to be transparent and compliant with applicable laws, while maintaining flexibility for essential political data uses.

Data Processing for Political Purposes

We collect and process personal data primarily to advance political and campaign objectives. This can include information such as your name, contact details, demographic data, voter registration details, voting history, political party affiliation, donation records, and opinions or issues of interest. We may obtain this information directly from you (for example, if you fill out a form, make a donation, or give us your contact at an event) as well as from public voter databases or third-party data providers. For instance, we might use publicly available voter registration lists or purchase voter data from state sources to identify likely supporters. We may also enhance our records with data from reputable analytics firms or data brokers to better understand your interests and tailor campaign outreach.

Use of Collected Data: All information we collect is used for legitimate political purposes in connection with campaigns and causes we support. This includes:

• Voter Outreach and Engagement: We analyze voter data to segment audiences (e.g., by geography, voting history, or issues) and craft targeted campaign messages. This helps us and our campaign partners send you relevant communications about candidates or initiatives you might care about. For example, we may combine voter file information with other consumer data to predict voting preferences and communicate more effectively.
• Fundraising and Donor Management: If you are a donor or potential donor, we use your information to process contributions, manage donation records, and plan fundraising strategies. Donor data (such as donation amounts or past political contributions) may be used to personalize fundraising appeals and ensure compliance with campaign finance laws (e.g., tracking donation limits and reporting requirements).
• Campaign Strategy and Research: We may use personal data to conduct political analysis, such as polling or modeling, and to produce insights that guide campaign decisions. This can involve aggregating supporter information to understand trends or running analytics to measure campaign effectiveness. All such processing is done to further political speech and advocacy efforts.
• Polling and Poll Data Collection: We engage in polling activities to gather opinions and sentiments from a broad audience. This involves collecting responses from individuals on various political, social, and economic issues. Poll data helps us understand public opinion trends and refine campaign strategies. When participating in our polls, you may be asked to provide personal details such as age, gender, political affiliation, and opinions on specific topics. We analyze this data to produce aggregated reports that inform campaign directions and policy positions.
• Service Delivery and Operations: In addition to campaign-specific uses, we might process data to operate our services – for example, maintaining our contact databases, communicating with you (responding to inquiries or providing updates), and improving our consulting services. If you sign up for newsletters or updates, we will use your email to send those communications (with the ability to unsubscribe, as described below).

We handle political data with sensitivity and in accordance with any applicable laws or ethical guidelines. We will not use personal information collected for a campaign for purely commercial, non-political purposes without your consent. We use data solely to advance campaign goals, advocacy, or similar purposes consistent with why the data was collected.

Data Sharing with Third Parties (Broad Data-Sharing Provisions)

To effectively run political campaigns and provide our services, we may share personal information with a variety of third parties. We do so in a controlled manner and only as necessary for the purposes outlined in this Policy. Such third-party sharing may include:

• Campaign Partners and Clients: We share relevant data with the political campaigns, candidates, or committees that we work for or in partnership with. For example, if you sign up to volunteer or donate through a campaign we manage, your information will be accessible to that campaign organization. We may also share data with affiliated political committees, political parties, or coalitions working on related causes. This could include sharing voter or supporter lists with organizations, candidates, or groups that have aligned political objectives or facilitate communication among like-minded causes.
• Political Affiliates and Like-Minded Organizations: We reserve the right to share data with organizations that have similar political viewpoints or goals. This means your information may be disclosed to advocacy groups, PACs, or campaign committees that are working toward objectives in line with those of our clients. Such sharing is intended to coordinate campaign strategies and broaden outreach for causes we believe you support. We will only do this as permitted by law and, where required, will obtain your consent or provide an opportunity to opt out.
• Service Providers and Vendors: We employ trusted third-party service providers to perform functions on our behalf. This includes data analytics firms, polling companies, marketing and mailing vendors, telemarketing or texting platforms, payment processors for campaign donations, IT and cloud hosting services, and other consultants. These service providers may access personal information only to the extent needed to perform their services for us. For example, an analytics provider might receive voter data to help us model voter turnout, or a payment processor will receive donor billing information to process a credit card donation. We contractually require these vendors to safeguard your data and use it solely for the purposes we specify.
• Media and Advertising Agencies: In executing campaign media strategies, we may share certain information with media buyers, advertising networks, or press agencies. For example, if we are running a targeted ad campaign, we might provide a list of zip codes or demographic profiles to an advertising agency to focus ads on those audiences. If we create campaign advertisements featuring supporter testimonials or stories (with consent), we might share relevant details with media outlets for publication.
• Social Media and Online Platforms: We may use social media platforms to reach voters and supporters, which can involve sharing data with those platforms. For instance, we might upload a list of supporter email addresses or phone numbers (in hashed or encrypted form) to platforms like Facebook, Instagram, Twitter, or Google to create “Custom Audiences” for campaign ads. This allows us to show you or people similar to you targeted political advertisements on those platforms. The platforms do not get to keep or use that data for their own purposes beyond the campaign advertising, and they will match the list against their user base to serve the ads. We do not receive personal data from the platform in return (only aggregate results, like how many people saw an ad). If you interact with our content on social media (such as liking a post or filling out a petition via a social media ad), the information you provide will be handled by us under this Policy and possibly also by the platform under its own privacy policy.
• Analytics and Tracking Partners: We may share certain online data (like cookies or website usage information) with analytics providers (e.g., Google Analytics) or advertising technology partners. These partners help us understand how people use our website or respond to campaign messages, enabling us to improve user experience and campaign effectiveness. For example, we might use cookies to track website visits and then use that data to identify people who showed interest in our content, and an analytics partner may receive that data to provide insights. Any third-party analytics or ad partners will be obligated to handle data in compliance with applicable privacy requirements (and where required, we will obtain consent for placing cookies or similar trackers). Once you opt out, we will refrain from sharing your personal data with third-party advertising partners or campaign affiliates for targeting purposes. However, you may still see political ads – they just won’t be specifically tailored using your personal data from us. Also note, opting out of targeting does not entirely remove your data from our systems, and we may still process it for other purposes (like internal analytics or to fulfill campaign obligations). It simply stops certain uses of your data for personalized advertising going forward.
• Legal Compliance and Protection: We may disclose personal information to third parties such as attorneys, auditors, law enforcement, regulators, or governmental authorities if necessary to comply with a legal obligation or respond to lawful requests (e.g., subpoenas or court orders). For example, U.S. campaign finance laws require disclosure of certain donor information to the Federal Election Commission (FEC) for donations above certain thresholds, which then becomes public record. We will also share data if needed to protect our rights and the rights of others, to investigate fraud or security issues, or as evidence in the event of a dispute.
• Business Transfers or Reorganizations: In the unlikely event that our firm undergoes a merger, acquisition, or other business reorganization, personal data may be transferred to the successor entity as part of that process. If so, your information would remain subject to the promises made in this Privacy Policy (unless you’re notified of changes and given a chance to opt out).

No Unrestricted “Sale” of Personal Data: We do not sell your personal information to unaffiliated companies for their independent commercial use. In other words, we do not exchange your data for money to data brokers or telemarketers to market unrelated products. However, please note that “sharing” data with our campaign partners or using it for targeted advertising might be considered a “sale” under certain privacy laws (like CCPA) due to broad definitions. We address how you can opt out of such sharing in the Consent and Opt-Out section below. All data sharing we engage in is aimed at furthering political and campaign purposes as described, and we take steps to ensure third parties use the data only for those intended purposes.

Public Sharing of User-Generated Content

We may publicly use content that you choose to share with us or post on our platforms. This includes any user-generated content such as comments, testimonials, endorsements, posts on our website or social media pages, or any feedback you provide about our services or campaigns. By submitting or posting such content, you acknowledge and agree that it may be used or published publicly for marketing, reporting, case studies, or political analysis. For example, if you leave a testimonial about our campaign services or a comment supporting a candidate on our site, we might quote that content (possibly along with your first name and last initial or other attribution you provided) in our promotional materials, reports, or on social media. Similarly, if you tag us or interact with us on social media with public comments, we may re-post or highlight those interactions.

License to Use Content: You retain ownership of any original content you create. However, by providing or posting content to us, you grant Sutton & Smart LLC a worldwide, non-exclusive, perpetual, royalty-free license to use, reproduce, edit, publish, display, distribute, and otherwise utilize that content in any media for our business purposes. This means, for example, we have your permission to use a testimonial you wrote in a campaign case study or to include your comment in a report, without further notice to you. You will not be entitled to any compensation for such use of your publicly provided content. Moreover, user-generated content is not considered confidential – any information you include in a public post may be viewed by others. Please think carefully before sharing personal details publicly in any content you submit, as we cannot control how other audiences might use that information.

We reserve the right (but not the obligation) to monitor, edit, or remove user-generated content on our platforms that we deem inappropriate or sensitive, in line with our community standards. If we decide to publicly use your content and you later wish to retract it (for instance, you no longer want your testimonial displayed), you may contact us and we will attempt to accommodate your request going forward. However, we cannot guarantee removal of content that has already been published or distributed, and archival copies may remain on our systems or third-party sites.

Legal and Compliance Considerations

We operate in accordance with applicable privacy laws and industry standards to ensure your data is handled properly. Our approach is to be transparent about our practices and to give users appropriate control, even in areas where strict privacy laws may not directly apply to political activities. Below are key legal considerations and how we address them:

• U.S. Privacy Laws (e.g., CCPA): We comply with relevant United States data privacy laws. In particular, if you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) regarding your personal information. These include the right to know what categories of personal information we collect, the right to request deletion of personal information (with certain exceptions), and the right to opt out of the sale of personal information. California law broadly defines “sale” to include certain data sharing, so even though we do not sell data for profit, our use of cookies or sharing of data with campaign partners might fall under this definition. Sutton & Smart will honor valid requests from California residents to exercise their CCPA rights. If you are a California resident, you can contact us as described below to: (a) Request a report of the personal information we have about you and how we have used or shared it; (b) Request that we delete personal information we collected from you, to the extent required by law (note: we may decline deletion requests if the information is necessary for us or our clients to fulfill legal obligations or other CCPA-recognized exemptions, such as completing transactions, ensuring security, exercising free speech, or other internal uses); and (c) Opt out of any “sale” of your personal information, including instructing us not to share your data with certain third parties for targeted advertising. We will not discriminate against you for exercising these rights. To make any CCPA-related request, please see the Contact Us section below. We may need to verify your identity before fulfilling your request (as required by law) and will respond within the timeframe mandated by CCPA.
• International Data (GDPR and other laws): If you are located in the European Economic Area (EEA), United Kingdom, or another region with data protection laws (such as the EU General Data Protection Regulation (GDPR) or similar regulations), you may have additional rights regarding your personal data. Subject to applicable law, these rights can include the right to access your data, correct or rectify inaccurate data, erase your data, restrict or object to certain processing, and the right to data portability. You also have the right to withdraw consent where we rely on consent, or to object to our processing when we rely on legitimate interests, to the extent provided by law. To the extent we engage with individuals in the EEA/UK, our lawful basis for processing personal data will typically be your consent (for example, when you sign up to a campaign newsletter or explicitly provide data for campaign engagement) or our legitimate interests in supporting democratic participation and free expression (recognizing that political communication can be a legitimate interest, balanced against individual rights). In some cases, we may also rely on legal obligations (such as complying with election laws) or public interest grounds. We will honor validated requests to exercise GDPR rights in accordance with applicable law. For example, if you are an EU citizen and want to access the information we have about you or have it deleted, you can contact us to request that. Note that GDPR also considers data about political opinions to be sensitive, so if any data we hold falls under special categories, we will handle it with the higher protections required. If you withdraw consent for processing, we will cease processing your data going forward, but this will not affect the lawfulness of past processing based on consent before its withdrawal. Additionally, other lawful grounds may allow us to continue certain processing even after consent is withdrawn. If you have concerns about our data practices, EU and UK individuals have the right to lodge a complaint with their data protection authorities, but we encourage you to contact us first so we can address your concerns.
• Election and Campaign Finance Laws: We abide by all relevant campaign finance regulations regarding the handling of personal data of voters and donors. As mentioned, if certain donor information must be publicly disclosed under U.S. law (for example, donors giving over $200 to a federal campaign are reported to the FEC), we will comply with those legal requirements. However, we will not use personal information obtained solely from public campaign finance reports to solicit new contributions or for commercial purposes, in accordance with federal law. We also adhere to laws regarding communications (such as honoring “Do Not Call” lists for telephone outreach where applicable, and obtaining proper consent for text messages in compliance with the Telephone Consumer Protection Act). Where state laws impose additional restrictions on political data (for instance, some states restrict use of voter registration data to political purposes only), we will use the data only for permitted purposes.

We continuously monitor our compliance with evolving privacy laws. Our commitment is to meet the requirements of laws like CCPA, GDPR, and any other applicable regulations, even if certain political activities may be exempt or treated differently under those laws. We believe in protecting privacy as a best practice and part of maintaining trust with the public. If a particular law grants you additional rights or if you have questions about how we comply with it, please reach out to us.

Consent and Opt-Out Mechanisms

We aim to provide you with control over your personal information. By engaging with our services or voluntarily providing information, you consent to the data practices described in this Policy. However, you have choices in how your data is used and shared, and you may opt out of certain activities as described below. We make efforts to honor your preferences while noting that in some cases we must retain or continue processing data for legal or operational reasons. Here are the ways you can manage your privacy with us:

• Marketing Communications: If at any time you prefer not to receive campaign emails, newsletters, or promotional updates from us or our clients, you can opt out. Email communications will include an “Unsubscribe” link that you can click to stop further emails. If we send you text messages (SMS) for campaign updates or voter outreach, those messages will include instructions to opt out (such as replying “STOP”). Once you opt out, we will remove you from the respective marketing list. Please note that even if you opt out of promotional communications, we may still send you non-promotional messages that are necessary for our services or a campaign – for example, a receipt for your donation, responses to your direct inquiries, or important notices about elections or changes to this Privacy Policy. These service or legally-required messages are not subject to general opt-out.
• Targeted Advertising and Data Sharing Opt-Out: If you do not want us to use your information for targeted online advertising or to share your data with third parties for those purposes, you have the right to opt out. For California residents, this is the “Do Not Sell or Share My Personal Information” right under CCPA. You can exercise this by contacting us at the email or phone number below with a request to opt out of targeted advertising or data sharing. Additionally, if our website uses cookies that facilitate targeted ads, you can refuse or disable those cookies via our cookie consent banner or your browser settings. We also honor any legally recognized browser signals for opt-out (such as the Global Privacy Control) if applicable. Once you opt out, we will refrain from sharing your personal data with third-party advertising partners or campaign affiliates for targeting purposes. However, you may still see political ads – they just won’t be specifically tailored using your personal data from us. Also note, opting out of targeting does not entirely remove your data from our systems, and we may still process it for other purposes (like internal analytics or to fulfill campaign obligations). It simply stops certain uses of your data for personalized advertising going forward.
• Consent Withdrawal: If we are processing your personal information based on your consent (for example, you consented to share a personal story for a campaign), you have the right to withdraw that consent at any time. You can contact us to let us know you withdraw consent for a particular use. We will then stop the processing of your data that was based on consent. However, any processing already done cannot be undone, and withdrawing consent will not affect uses of your data that were done before the withdrawal. In some cases, we might have an alternate legal basis to continue handling your data even after you withdraw consent (for example, we may need to retain a record of a donation for compliance reasons), and if so we will inform you. But we will not continue the specific activity you objected to if we have no legal need to keep doing it.
• Access, Correction, or Deletion Requests: You may contact us at any time to request information about the personal data we hold about you, or to ask that we correct any inaccuracies. We will endeavor to provide you with a summary of your information and correct any verified inaccuracies upon request. You may also request that we delete personal information we have collected from you. We will honor deletion requests to the extent required by law or our internal policies. Keep in mind there are situations where we cannot fully comply – for example, if the data is required to complete transactions, to comply with legal obligations, for security, or if the data is part of an aggregated dataset that does not identify you directly. If we must retain certain data, we will explain the reasons. Otherwise, we will delete or anonymize your information and instruct our service providers to do the same.
• Opt-Out of Sharing with Political Affiliates: If you have provided information to a campaign we manage and you do not want your data shared with other allied campaigns or political organizations, please let us know. While our default practice may be to share supporter data within related campaigns (as described in the Data Sharing section), we respect individual preferences. For instance, if you are a donor or volunteer and you inform us that you don’t want to be contacted by other candidates, we can flag your record to not include it in any list-sharing. We will honor such requests as best as we can. Note that if your data was already shared prior to your request, we cannot retract it from other entities, but we will cease further sharing going forward.

No Absolute Data Control: We will do our best to honor all the aforementioned requests and preferences. However, it’s important to understand that no organization can offer complete, absolute control over data in all circumstances. There may be residual copies of your information in backups or archives that are infeasible to remove immediately. Certain data might have been shared (with consent or as permitted) and already lawfully used by others in ways we cannot erase. Our obligation is to comply with the law and make reasonable efforts to accommodate your privacy preferences without compromising our ability to operate effectively and lawfully. We therefore cannot promise that we will be able to prevent all data processing relating to you (for example, public voter records might still be accessed by others, or we might need to keep basic information to avoid re-contacting you after you opt out). What we do promise is to be transparent about how we use data, to give you choices and rights as described, and to not misuse your personal information in ways that violate this Policy or applicable law.

Data Security and Retention

We take data security seriously and implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, loss, or misuse. This includes measures like access controls restricting who within our organization and our partners can see your personal data, encryption and secure protocols for sensitive data transfers (for example, encrypting donor credit card information during processing), and storing data in secure systems. While we strive to protect your information, no security measures are infallible. Thus, we cannot guarantee 100% security of data at all times. In the event of a security breach affecting your personal information, we will notify you and any required authorities in accordance with applicable breach notification laws.

We retain personal information only as long as necessary for the purposes described in this Policy, unless a longer retention period is required by law or justified by a legitimate business need. For example, we may keep voter or supporter data throughout an election cycle and for a reasonable period afterward for analysis or historical record. Donor records may be retained to comply with financial reporting laws. When personal data is no longer needed, we will securely delete or de-identify it.

Children’s Privacy

Our services and campaigns are not directed to children under the age of 13, and we do not knowingly solicit or collect personal information from anyone under 13 years old. If you are under 13, please do not provide information to us or participate in our online features. If we become aware that we have inadvertently collected personal data from a child under 13, we will promptly delete such information from our records. For minors aged 13–17, we encourage parents or guardians to be involved in their online activities. Any information collected from minors in this age range (for example, a 17-year-old volunteering for a campaign) will be handled with additional care consistent with applicable laws and the minor’s privacy rights.

Updates to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, operational needs, or legal requirements. Updated versions will be posted on our website with a new “Last Updated” date. If we make substantial changes to how we handle your personal information, we will provide a prominent notice (e.g., on our homepage or via email notification, if appropriate). We encourage you to review this Policy periodically to stay informed about how we protect your information. Your continued interaction with us after any changes to this Policy signifies your acceptance of the revised terms.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Sutton & Smart LLC
Attn: Privacy Officer
1234 Campaign Way, Phoenix, AZ 85001, USA
Email: privacy@suttonsmart.com
Phone: +1 (602) 555-1234

You may reach out to us to exercise your rights as described above or to ask any questions about how we handle personal data. We will respond as promptly as possible. If you are not satisfied with our response, and applicable law provides, you may have the right to contact your state Attorney General’s office or data protection authority to lodge a complaint.

By using our services or providing personal information to us, you acknowledge that you have read and understood this Privacy Policy. We appreciate your trust in Sutton & Smart LLC and are dedicated to honoring your privacy while effectively pursuing the political objectives of our clients within the bounds of the law and good practice.