Privacy Statement
Last updated: December 5, 2024
Last updated: December 5, 2024
- Introduction
- What types of personal information we collect about you
- How we collect personal information about you
- How we may use your personal information
- With whom we may share your personal information
- Donor Privacy
- Internet activity information
- Our data security protections
- Your privacy rights and choices
- Notices and disclosures
- How to contact us
- Updates to this privacy statement
- Categories of Personal Information We Collect
- How We Collect Personal Information
- How We May Use Your Personal Information
- Donor Privacy
- RETENTION
- Your Privacy Rights and Choices
- Notices and Disclosures
- Representing veterans and their families with VA claims for benefits;
- Sending communications about DAV services and programs;
- Providing a safe user experience on our Site;
- Sending communications to you to let you know about what we are doing with your donations and to solicit additional donations;
- Protecting users, our employees, our volunteers, and our property;
- Analyzing and improving our operations (e.g., optimizing the design and operation of our Site); and
- Managing legal issues.
- How to Contact Us
- Updates to this Privacy Statement
Disabled American Veterans (DAV) values your trust, and we understand the importance of protecting your privacy. We want to make sure that you understand how your information is collected and used by DAV. This privacy statement (“Privacy Statement”) describes what information we collect about you, including when and how we collect it; how we use it; with whom we may share it; and what choices you have regarding our use of your information. Please note this Privacy Statement is made on behalf of DAV and the DAV Auxiliary (hereinafter collectively referred to as DAV).
The DAV Charitable Service Trust (“CST”), DAV National Service Foundation (“NSF”) and Disabled Veterans’ Life Memorial Foundation (“DVLMF”) are subject to this Privacy Statement with consideration that several of DAV’s privacy practices are not applicable to these organizations. For instance, these organizations neither have members or employees nor represent veterans and their families before the VA. Moreover, the organizations engage in limited fundraising initiatives, if at all.
This Privacy Statement applies to all information collected from you through communications with DAV, whether electronic, written or oral; information collected through DAV-branded systems and mobile applications (“Systems”) and DAV websites (“Sites”), offline or that we receive from third parties; as well as any other information about you that we may collect through your use of our programs and services, (collectively, Apps, Sites, and offline or third-party information are referred to as the “Services”). By accessing our Services or providing your information to us, you accept and agree to the practices described in this Privacy Statement.
This Privacy Statement describes our privacy practices. The links in the table of contents below go straight to more detailed information on that topic.
When you engage with DAV or visit or use our Services, we collect a variety of information. In general, the type and amount of information we collect on you will depend on how you choose to interact with DAV. For instance, if you are retaining DAV to represent you in obtaining benefits before the United States Department of Veterans Affairs (VA) or otherwise contacting us for assistance, we will need different information than if you are using our website to gather information on veteran-related topics or donate to DAV.
DAV collects information that identifies you as an individual or information which is linked or linkable to you as an individual, collectively referred to throughout this Privacy Statement as “Personal Information.” The specific categories include contact information, demographic information, health information, financial information, social media information, employment information, internet (web) activity information including information from cookies and information on children. These categories are explained further below.
Contact Information and Preferences. We may request contact information such as your name, mailing address, telephone number, email address, and your preferences for how you would like to be contacted by DAV. We may also use third-party services to supplement or ensure accuracy of contact information. we run addresses through address correction services.
Demographic Information. We may also ask you for certain demographic information, such as your date of birth or age, your geographic location, and/or marital status. We may also use publicly available data or third-party services to supplement this information. We use demographic information to help us understand the populations we serve and to determine how we can better serve people and communities. We may ask for race or ethnicity and gender identity if an individual registers and attends DAV Patriot Boot Camp and other events. We do request this information for any other purpose. We do not collect certain demographic information, including sexual orientation, religious beliefs, citizenship or citizenship status, or genetic or biometric data.
Health Information. With your expressed consent, DAV may collect health information in limited circumstances, which are discussed in greater detail under the section titled “How We Collect Personal Information”.
Financial Information. If you make a donation to DAV, become a member or make a retail purchase on our online store, we may collect payment information such as your credit card number to process your transaction. We may use a third-party payment service to process payments. We will retain your credit card information only for as long as necessary to process the transaction.
Social Media Information. We may collect social media identifiers and/or interests or opinions expressed if you engage with us directly on social media platforms.
Employment Information. If you apply for employment with us, volunteer your professional services, or participate in engagement activities such as DAV Homeless Stand Down, we may collect employment information including title and organization with whom you work or have worked.
Internet Activity. We may collect web server traffic activity and history on DAV Sites which may be tied to your Internet Protocol address or device type. We use this information to measure engagement on the Sites, effectiveness of our campaigns and to determine areas of interest of our constituency.
Information on Children. Digital privacy is a component of DAV’s commitment to youth protection and safety. Expect in limited circumstances, our Services are not directed to children, and we do not knowingly collect Personal Information from children without obtaining parental consent. With parental/legal guardian consent, DAV may collect Personal Information of individuals under 18 years of age for purposes of event participation in addition to volunteer, scholarship and membership opportunities. In the unlikely circumstance we discover that we have collected Personal Information from a child other than as described in this section, we will delete the information immediately.
DAV and its service providers may collect Personal Information in a variety of instances. For example, we may collect information about you in the following circumstances:
National Service Program. Although DAV operates a number of charitable programs that serve the interests of its constituency, its marquee program, and the one for which it is best known, is the National Service Program. Through that program, and from approximately one hundred locations around the United States and Puerto Rico, DAV’s service officers provide free assistance to veterans with their claims for benefits from the VA. If you retain DAV to assist you with receiving your VA benefits, you consent to allowing DAV to have access to your Personal Information and health information (specifically your VA file). DAV does not keep copies of VA files or any medical records the file contains. With that being said, certain health information may be noted in DAV’s proprietary case management system and in legal briefs/submissions filed on your behalf.
Membership Applications. DAV has more than a million members, all of whom are service-connected disabled veterans. DAV’s membership application requests certain health information about a veteran’s service-connected disability. With your expressed consent, this information may be stored electronically so that we can let you know about services and programs that may assist you.
Site and App Use. We may collect Personal Information through your use of the Sites and mobile applications.
Donations and Bequests. If you donate to DAV or represent an estate or trust that gives to DAV, we will collect Personal and Demographic Information from you that may include: your name, address, telephone number, and/or email address so that we can send you a receipt and thank you for your donation. We will then store your data in our Systems for purposes addressed in Section IV unless you expressly opt-out. We may also collect limited financial information to process your donations, but we do not save or store financial information.
Employment or Volunteer Participation. If you seek employment with DAV or volunteer for DAV, we will collect information related to your role. For instance, we will collect employment history information if you submit a resume to DAV. We may also request a background check. If you are volunteering, we may ask about your geographic location and the languages you speak. Or, if you are volunteering to provide transportation assistance through our Transportation Network Program, VA will perform a background check.
Event Registration. DAV hosts many events annually around the United States. If you register for an event, we will collect Personal Information and limited Demographic Information on you.
Third-Party Fundraising Campaigns, Promotions, or Events. We may use or interact with third-parties to conduct fundraising campaigns and to assist with registration for certain events. In these instances, we may receive access to donor reports which includes donor name, contact information, and donation amount. We also may receive your Personal Information if you respond to a campaign or other promotion benefitting DAV that is conducted by a corporate partner.
We and our service providers may use Personal Information for the following purposes:
Mission Delivery and Support Operations. The collection, use, and disclosure of your Personal Information will be consistent with our mission to serve the interests of the nation’s disabled veterans. These activities include mission support operations such as data analysis, program improvement, fundraising events, and activities.
Data Analytics. We use data to evaluate engagement levels with our Sites and programs. We also perform data analysis and research activities to gain a greater general understanding of the needs of veterans, their families and their caregivers. When we perform data analytics, we may also use information that has been anonymized or aggregated in a manner that it no longer reveals your specific identity.
Targeted Fundraising. We may use certain information (name, address, telephone number, email information, date of birth, dates of military service, etc.) to contact you for the purpose of raising money for DAV, but you may opt-out of certain communications or request deletion of certain data. Please note if you subsequently reengage with DAV, you will need to submit a new request to opt-out. Please note you are free to opt-out of fundraising solicitations and your decision will have no impact on your ability to receive services from DAV.
Other Business Purposes. We may use Personal Information for other business purposes, such as conducting audits, fraud monitoring and prevention, data analysis, recordkeeping, developing new services, enhancing, improving, or modifying our Systems and our Services, identifying usage trends, determining the effectiveness of fundraising campaigns and mission activities, and updating and expanding our business activities.
With your consent. In addition to the other uses described in this section, we may also use your information as you expressly authorize us to do so.
Except for the limited purpose outlined herein and in Section VI below, DAV does not share or sell Personal Information of its constituents. Constituents as used throughout this Privacy Statement include members, donors, volunteers, and individuals DAV represents before the VA. DAV does share Personal Information with its service providers, program volunteers, and other third-parties that assist DAV in furtherance of its mission; Personal Information is only shared with these third-parties pursuant to confidentiality requirements. In furtherance of our mission, your Personal Information may be shared with the following categories of third parties: service providers, mission collaborators, volunteers, individuals in his whose name you donated, or immediate family members (memorial donations), and others with your consent or as required by law.
Third-Party Service Providers. We may need to share Personal Information with third parties that provide operational services on our behalf (such as website hosting, information technology and infrastructure, data analytics, email delivery, order fulfillment, auditing, or other services) or that assist DAV in providing you with support and resources. DAV also uses third-party vendors to facilitate fundraising and membership activities on its Systems and Sites and in offline business operations. The information that you submit on DAV’s Systems and Sites or through other communications may be provided to those vendors on a confidential basis.
Mission Collaborators. We may also collaborate with organizations to provide or improve DAV’s services and operations. For example, in the case of DAV-related co-branded promotions that support the fulfillment of DAV’s mission, DAV permits mailings and emails to its members. The mailings and emails are produced and sent by third-party data management and mailing companies selected by DAV, and in limited cases, DAV may provide information directly to the promotion partner. The member information provided to the data management and mailing companies and promotion partner is at all times subject to strict nondisclosure requirements.
We will not share your Personal Information that we have collected directly from you with third-parties for those third-parties’ direct marketing purposes unless you have consented (either though an opt-in or opt-out opportunity).
Volunteers. We may share limited Personal Information, such as contact information, with volunteers who are assisting DAV and who require the information as part of their duties.
Social Media. If you engage with DAV on a public, social media platform, you may be sharing your Personal Information with your friends associated with your social media account, to other website users, and to your social media account provider, in connection with your social sharing activity. By connecting your DAV account with your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media provider’s privacy policy. Please note that any information you post within these public forums or social media pages may become public and may be read, collected, and used by anyone. Please exercise caution when deciding whether to disclose your Personal Information in these forums.
Other Uses or Disclosures of Personal Information. We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; and (b) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
Your Consent. In addition to the other disclosures described in this section, we may also disclose your information as you expressly authorize us to do so.
Third-Party Cooperatives
DAV shares Personal Information (including name, contact information, and donation history) in the context of cooperatives managed by third-party vendors, such as Wiland and Apogee. DAV may also rent names directly to organizations and companies through use of a data-broker.
The personal information provided is used by the third-party vendors to create an aggregated score or profile which may then be used to send solicitations on behalf of other organizations. These organizations will not have direct or continued access to your Personal Information unless you choose to provide it to them directly. We do not share health-related data in connection with these efforts.
You, as a donor, may have your name excluded from any donor list-sharing activity by submitting an opt-out request.
Internet Activity Information
DAV may also collect information that does not reveal your specific identity or does not directly relate to an identifiable individual, referred to throughout this Privacy Statement as “Internet Activity Information,” including browser and device information, App usage data, Internet Protocol address, and information collected through cookies, pixel tags, and other technologies.
Browser and Device Information. Certain information is collected by most browsers or automatically through your device, such as your computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
DAV App Usage Data. When you download and use DAV-branded Apps, we and our service providers may track and collect App usage data, such as the date and time your device accesses our servers and what information and files have been downloaded to the App based on your device number.
Internet Protocol Address. Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering the Services. We may also derive your approximate location from your IP address.
Web Server Traffic Pattern Information and Browsing History. We collect standard web server traffic pattern information and your browsing history on DAV Sites. General traffic, Site usage, browser information, and length of stay information are collected and stored in log files.
Cookies
We use “cookies,” small files that are sent to your web browser and stored on your computers hard drive, to enhance your online experience. The cookies collect information about your use of our Services, such as the type of browser you use, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the website), how you were directed to the Services, which specific pages you accessed, how long you view each page, the time and date you access our Services and anonymous traffic data.
Using pixel tags and other similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the online actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
Targeted Outreach and Advertising
We may work with third-party service providers to target our advertisements and outreach to you based on your preferences or internet activity information, in certain cases combining data we collect from you through online cookies and other technologies with other de-identified data (such as a hashed, non- readable email or postal address). In addition, we may use third-party service providers to display content-specific advertisements to you after you have left our Sites when you go to other websites. These third-party service providers may use cookies, web beacons, or similar technologies, to tailor advertisements to interests shown by browsing our Sites or other by visiting other websites. We do not control the third-party service providers’ tracking technologies or how they may be used. The collection of your information or use of technologies by third-party service providers are subject to those third parties’ privacy policies, not DAV’s.
Do Not Track
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. We do not currently respond to browser do-not-track signals at this time, as it has not gained widespread acceptance.
Analytics
We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
De-Identified or Aggregate Information
We use De-Identified Information and Aggregate Information for activities including data analysis and research to gain a greater general understanding of veterans’ needs and the related needs of their families and their caregivers. “De-Identified Information” means information where identifiers have been removed so that it does not directly or indirectly identify and cannot reasonably be used to identify an individual. “Aggregate Information” means information about groups or categories of individuals which does not identify and cannot reasonably be used to identify an individual. For example, we may use Aggregate Information to compare the types of services our Constituents utilize in one geographic location with another to understand how the two groups are different or similar.
Our Data Security Protections
We seek to use reasonable organizational, technical, and administrative measures reasonably designed to secure the information to protect Personal Information within our organization. We incorporate industry standard security controls (like firewalls) and protocols (like SSL/TLS) to create a site that is resistant to standard internet-based threats. Moreover, your Personal Information is located on secure servers and encrypted before it hits our third-party storage providers’ servers. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to Contact Us” section below.
DAV retains Personal Information that we receive for as long as necessary to fulfill the purpose(s) for which the information was collected, to provide our services and products, to pursue legitimate business purposes, to enforce our agreements, and comply with all applicable laws.
In certain states, such as Colorado, you have specific rights regarding your Personal Information. This section describes your rights and explains how to exercise those rights. Subject to certain limitations (such as our legal obligations), you have the right to access, to obtain a copy of, to correct, to opt-out of sharing, and to delete your Personal Information. You also can limit the means or frequency of certain communications by completing and submitting an opt-out request.
To Access/Request a Copy of your Personal Information
Subject to applicable law, you may have the right to obtain confirmation of the categories of Personal Information DAV maintains about you and/or to request access to and receive a copy of information. To exercise your privacy rights, please submit your request to [email protected]. In your request, please make clear what Personal Information you would like to review. For your protection, we must verify your identity before implementing your request. If you are submitting a request on behalf of someone else, we may ask for additional verification, such as written documentation or other proof of authority. We will try to comply with your request as soon as reasonably practicable, consistent with applicable law.
To Opt-Out of Sharing
You have the right to opt out of the sharing of your data. To exercise this right, please submit an opt-out request form.
To Request Deletion
You have the right to request that we delete any of your Personal Information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our Systems. Please contact [email protected] to request deletion of your data.
Please note that in cases of deletion, limited Personal Information will remain to document the request.
Right to Appeal
Although DAV makes good faith efforts to comply with privacy rights requests, there may be circumstances in which DAV is unable to provide access, including but not limited to, where the information would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the information is subject to legal privilege.
If you exercise one of your privacy rights and we are unable to process your request, a request for appeal may be submitted to [email protected].
Communication Preferences and Restrictions
We recognize that you may wish to control or limit the ways in which we contact you and/or share your Personal Information, including for fundraising purposes. An “Unsubscribe” button will be provided at the top or bottom of each email/SMS marketing communication sent by DAV or by a third-party vendor on its behalf, so that you may opt-out of further email/SMS communications. However, we will continue to send transaction-related emails regarding our relationship and the Services you have requested. If you later reengage with DAV, you must submit a new opt-out request.
To inform us of any desired communications restrictions, please submit an opt-out request. If you contact us with an opt-out request, we will honor the request in accordance with timelines set forth in applicable law.
In the event we are appointed as your representative before the VA, please note any opt-out request is not applicable to data contained in our proprietary case management system.
Mobile Applications
You can stop collection of information by mobile applications easily by uninstalling the application. You may use the standard uninstall processes available as part of your mobile device or network. To discontinue the collection of geolocation data within a mobile application, you can modify your privacy settings on your mobile device.
Links to Third-Party Websites
Our Services may contain links to third-party websites, whose privacy practices may be different from DAV’s. This Privacy Statement does not address, and we are not responsible for, the privacy, information or other practices of any third-parties, including any third-party operating any website or service to which the Services link. Links to other sites do not imply DAV’s endorsement of the products or services or privacy or security practices of those websites. In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Sites or our social media pages.
Lawful Basis for Processing
The laws in certain states require us to tell you about the lawful grounds we rely on to collect, use, disclose, and otherwise process your Personal Information. To the extent those laws apply, we have several different lawful bases for processing your Personal Information including: (a) as necessary to provide a service or information you request; (b) to comply with legal obligations; (c) based on your consent, and (d) in support of our legitimate interests, where those interests are not overridden by your fundamental rights and freedoms. In certain cases, we process Personal Information because it furthers our legitimate business and charitable interests. This includes:
Jurisdiction and Cross-Border Transfer
DAV is headquartered in the United States and has service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country, or other location where privacy laws may not be as protective as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities may be entitled to access your Personal Information.
Information Provided on Behalf of Others
If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.
Privacy Questions and Communication Preferences
If you have any questions about this Privacy Statement, or if you wish to update or correct your personal profile, change your communication preferences or limit communications, please contact us at:
Phone Number: 859-442-1340 Email: [email protected] Address: P.O. Box 14301, Cincinnati, OH 45250-0301 If you have questions regarding your privacy rights or would like to appeal a response to your privacy request, please contact [email protected].
Security Breach or Fraud Notification. If you witness or become aware of any suspected privacy or security breach of DAV constituent data (i.e., mishandling, theft, loss, or improper disclosure of personal information) or potentially fraudulent activity, please email [email protected].
DAV may modify this Privacy Statement at any time. When changes are made, we will update the “last modified” section at the top of our Privacy Statement. Your use of DAV’s Systems and Services following these changes means that you accept the revised Privacy Statement.