Privacy Policy

Section 1

Introduction

Dr. Stephen Neal Jr. for Superintendent ("Campaign," "we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website drstephennealjr.com, interact with our forms, sign up for communications, donate, volunteer, or otherwise engage with our campaign.

By using our website or providing your information through any of our campaign channels, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access our website or provide your personal information.

Section 2

Information We Collect

We may collect the following categories of personal information when you interact with our campaign:

Information You Provide Directly:

• Identifiers: First name, last name, email address, phone number, mailing address, and ZIP code
• Volunteer & Engagement Preferences: How you would like to support the campaign (e.g., volunteer, sign petition, donate, host an event, stay informed)
• Donation Information: If you make a financial contribution, we may collect billing information as required by Federal Election Commission (FEC) and Arizona campaign finance reporting requirements, including name, address, occupation, and employer
• Communications: Any messages, feedback, or correspondence you send to us

Information Collected Automatically:

• Device & Browser Information: IP address, browser type and version, operating system, device type, and screen resolution
• Usage Data: Pages visited, time spent on pages, referring URLs, click patterns, and navigation behavior
• Cookies & Tracking Technologies: We use cookies, pixel tags, and similar technologies to enhance your experience, analyze website traffic, and measure the effectiveness of campaign communications. You may control cookie preferences through your browser settings
• Location Data: General geographic location derived from your IP address (city/state level only; we do not collect precise geolocation)

Section 3

How We Use Your Information

We use the information we collect for the following purposes:

• To communicate with you about campaign news, events, volunteer opportunities, and policy updates
• To send SMS text messages and email communications you have opted in to receive
• To process and acknowledge donations in compliance with FEC and Arizona state campaign finance reporting requirements
• To coordinate volunteer activities and community events
• To manage petition signature collection for ballot access
• To improve our website, campaign communications, and supporter experience
• To analyze website traffic, campaign performance, and engagement metrics
• To comply with applicable laws, regulations, and legal obligations
• To protect the rights, safety, and security of our campaign, supporters, and the public

Section 4

SMS / Text Messaging Policy

This section describes our practices regarding SMS and text message communications in compliance with the Telephone Consumer Protection Act (TCPA), Cellular Telecommunications Industry Association (CTIA) guidelines, and A2P 10DLC registration requirements.

Consent & Opt-In: We only send SMS messages to individuals who have provided express written consent by opting in through our website forms, events, or other campaign channels. Consent is obtained through a clear, separate opt-in mechanism that is not bundled with any other consent (such as email consent or agreement to terms of service). Opting in to receive SMS messages is not a condition of any purchase, donation, or service.

Types of Messages: Messages may include campaign updates, event notifications, volunteer coordination, petition and ballot access information, fundraising communications, and other campaign-related content.

Opt-In Data Privacy: We do not sell, rent, lease, or share your phone number or SMS opt-in consent data with any third parties for their marketing purposes. Opt-in data may only be shared with our campaign's authorized service providers (such as our CRM and messaging platform) solely for the purpose of delivering the messages you have consented to receive.

Supported Carriers: Major carriers supported include AT&T, T-Mobile, Verizon, Sprint, and most regional carriers. Carriers are not liable for delayed or undelivered messages.

Messaging Hours: We make commercially reasonable efforts to send messages only between 8:00 AM and 9:00 PM in the recipient's local time zone.

Section 5

Email Communications (CAN-SPAM Compliance)

We comply with the CAN-SPAM Act and all applicable federal regulations governing email communications. When you opt in to receive emails from our campaign, we will:

• Clearly identify all emails as coming from Dr. Stephen Neal Jr. for Superintendent
• Include a valid physical mailing address in every email
• Provide a clear and conspicuous unsubscribe mechanism in every email
• Honor all unsubscribe requests within 10 business days
• Not use deceptive subject lines or misleading header information

To unsubscribe from campaign emails, click the "Unsubscribe" link at the bottom of any email. You may also email us at [email protected] with the subject line "Unsubscribe" and we will promptly remove you from our mailing list.

Section 6

Information Sharing & Disclosure

We value your trust and are committed to protecting your personal information. We do not sell, rent, or lease your personal information to third parties for their marketing purposes.

We may share your information only in the following limited circumstances:

• Service Providers: We share information with trusted third-party service providers who assist with campaign operations, including our CRM platform, email service provider, SMS messaging platform, website hosting, payment processing, and analytics tools. These providers are contractually obligated to use your information only to perform services on our behalf and to maintain its confidentiality
• Legal & Regulatory Compliance: We may disclose information as required by law, including compliance with FEC reporting requirements and Arizona campaign finance laws. Donor information (name, address, occupation, employer, and donation amount) may be publicly reported as required by federal and state election law
• Legal Process: We may disclose information in response to valid subpoenas, court orders, or other legal processes, or to protect the rights, property, or safety of our campaign, our supporters, or the public
• Campaign Transfers: In the event of a campaign reorganization or transition, your information may be transferred to a successor organization, subject to the terms of this Privacy Policy

We do not share or sell SMS opt-in consent data or phone numbers with any third parties for their independent use.

Section 7

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and regulatory obligations, and resolve disputes. Specifically:

• Supporter & Volunteer Data: Retained for the duration of the campaign and for a reasonable period afterward to fulfill any post-election obligations
• Donation Records: Retained as required by FEC regulations and Arizona campaign finance laws (typically a minimum of 3 years after filing the relevant report)
• SMS & Email Opt-In Records: Retained for the duration of the subscription plus a reasonable period after opt-out to document consent compliance
• Website Analytics: Aggregated and anonymized data may be retained indefinitely for analytical purposes

When personal information is no longer needed, we will securely delete or anonymize it in accordance with industry best practices.

Section 8

Data Security

We implement commercially reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, use, alteration, and disclosure. These measures include:

• SSL/TLS encryption for all data transmitted through our website
• Secure access controls and authentication for campaign systems and databases
• Regular security reviews of our third-party service providers
• Limited access to personal information on a need-to-know basis among campaign staff and authorized volunteers

While we take reasonable measures to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

Section 9

Your Rights & Choices

You have the following rights regarding your personal information:

• Opt-Out of SMS: Text STOP to any campaign text message at any time
• Opt-Out of Email: Click the "Unsubscribe" link in any campaign email, or email us at [email protected]
• Access Your Data: You may request a copy of the personal information we hold about you
• Correct Your Data: You may request corrections to any inaccurate personal information
• Delete Your Data: You may request deletion of your personal information, subject to our legal retention obligations (such as FEC reporting requirements)
• Cookie Preferences: You may control cookies through your browser settings. Disabling cookies may limit certain website functionality

To exercise any of these rights, please contact us using the information in Section 14 below. We will respond to all requests within 30 days, or as required by applicable law.

Section 10

California Residents — CCPA/CPRA Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). While political campaigns and nonprofit organizations may be exempt from certain CCPA requirements, we are committed to transparency and extend the following rights to California residents as a matter of best practice:

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you in the preceding 12 months, the categories of sources from which it was collected, the business purpose for collecting it, and the categories of third parties with whom it was shared
• Right to Delete: You have the right to request deletion of your personal information, subject to certain legal exceptions
• Right to Correct: You have the right to request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information as defined under the CCPA/CPRA. Therefore, there is no need to submit a "Do Not Sell or Share My Personal Information" request
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights

Categories of Personal Information Collected (Past 12 Months):

• Identifiers (name, email, phone, mailing address, IP address)
• Internet or electronic network activity (browsing history, interactions with our website)
• Geolocation data (general location from IP address)
• Professional or employment-related information (occupation and employer for donors, as required by FEC)

To submit a CCPA request, please email [email protected] with the subject line "CCPA Request." We will verify your identity before processing your request and will respond within 45 days.

Section 11

Children's Privacy

Our campaign website and communications are not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If we discover that we have inadvertently collected personal information from a child under 13, we will promptly delete that information. If you believe a child under 13 has provided us with personal information, please contact us immediately at [email protected].

Section 12

Third-Party Links & Services

Our website may contain links to third-party websites, social media platforms, or services that are not operated by us. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the privacy practices or content of external websites.

Third-party services we may integrate with include social media platforms (LinkedIn, X/Twitter, Facebook), analytics providers (Google Analytics), our CRM and email/SMS platform (GoHighLevel), and payment processing services for donations.

Section 13

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this Privacy Policy periodically. Your continued use of our website and campaign services after any changes constitutes your acceptance of the updated policy.

For material changes that affect how we process your personal information, we will make reasonable efforts to notify you via email or a prominent notice on our website.

Section 14

Contact Us

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