1. Data Controller
The data controller responsible for your personal data is:
Black Veterans Project, Inc.
A 501(c)(3) nonprofit organization
P.O. Box 90294
Washington, DC 20090
United States
As data controller, we determine the purposes and means of processing your personal data and are responsible for ensuring your data is handled in compliance with applicable data protection laws.
2. Privacy Contact
For all privacy-related inquiries, data subject requests, or concerns about how we handle your data, contact our designated privacy contact:
Black Veterans Project
We aim to respond to all privacy inquiries within 30 days.
3. Data We Collect
We collect different categories of personal data depending on how you interact with us:
3.1 Information You Provide
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | First name, last name | Membership signup, contact forms |
| Contact Data | Email address, phone number, mailing address, ZIP code | Membership signup, newsletter, contact forms |
| Demographic Data | Race, gender identity | Advocate/Veteran membership forms (optional) |
| Military Service Data | Branch, service era, pay grade, discharge status, VA claim status | Veteran/Advocate membership forms |
| Personal Experiences | Barriers to benefits, personal hardships | Advocate/Veteran membership forms (optional) |
| Professional Data | Title, affiliation, LinkedIn profile, employment status | Advocate membership forms (optional) |
| Financial Data | Payment card details (processed by Donately, not stored by us) | Donations |
3.2 Information Collected Automatically
When you visit our website, we may automatically collect:
- Device Data: Browser type, operating system, device type
- Usage Data: Pages visited, time spent, scroll depth, click patterns
- Location Data: Country and region (derived from IP address, which we anonymize)
- Referral Data: How you found us (search engine, social media, email campaign)
Important: We only collect this data after you provide consent via our cookie banner. See Section 15: Cookies & Tracking.
4. How We Use Your Data
We use your personal data for the following purposes:
| Purpose | Description |
|---|---|
| Membership Management | Registering you as a member, maintaining membership records, segmenting members for relevant communications |
| Communications | Sending newsletters, updates on our work, calls to action, event invitations |
| Advocacy & Organizing | Coordinating petition drives, call campaigns, town halls, and rapid-response moments |
| Legal Resources | Connecting veterans with legal resources, including information about the Monk v. United States case |
| Donation Processing | Processing donations, sending tax receipts, donor acknowledgments |
| Website Improvement | Analyzing how visitors use our site to improve user experience |
| Legal Compliance | Complying with applicable laws and regulations |
5. Legal Basis for Processing
Under GDPR and similar laws, we must have a legal basis to process your personal data. We rely on the following:
| Legal Basis | GDPR Article | When We Use It |
|---|---|---|
| Consent | Art. 6(1)(a) | Newsletter signup, analytics cookies, marketing emails |
| Explicit Consent | Art. 9(2)(a) | Collecting sensitive data (race, military history, health-related barriers) |
| Legitimate Interests | Art. 6(1)(f) | Responding to contact form inquiries, website security, fraud prevention |
| Legal Obligation | Art. 6(1)(c) | Tax record keeping for donations, responding to legal requests |
Legitimate Interests Assessment: Where we rely on legitimate interests, we have conducted a balancing test to ensure our interests do not override your fundamental rights and freedoms. You may contact us to request details of this assessment.
6. Special Category Data
Some of the information we collect is considered "special category" data under GDPR Article 9, including:
- Racial or ethnic origin (e.g., identifying as a Black veteran)
- Health-related information (e.g., mental health challenges, addiction, disability status)
- Political opinions (implied by participation in advocacy activities)
We only collect this data with your explicit consent. When you complete our membership forms, you are asked to check a consent box specifically acknowledging that you are sharing sensitive information.
You may withdraw this consent at any time. See Section 11: Withdrawing Consent.
7. Who We Share Your Data With
We share your personal data with the following third-party service providers:
| Service Provider | Purpose | Data Shared | Location |
|---|---|---|---|
| Action Network | CRM, email marketing, membership management | Name, email, phone, address, membership data, form responses | United States |
| Vercel | Website hosting, analytics, performance monitoring | IP address (anonymized), pages visited, device info | United States (Edge network) |
| Donately | Donation processing | Name, email, payment information | United States |
| Substack | Newsletter publishing and distribution | Email address | United States |
We require all third-party processors to respect the security of your personal data and treat it in accordance with applicable law. We do not allow them to use your data for their own purposes; they may only process your data for specified purposes and in accordance with our instructions.
8. International Data Transfers
Black Veterans Project is based in the United States. If you are accessing our website from the European Union, United Kingdom, or other regions with data protection laws, please be aware that your data will be transferred to, stored, and processed in the United States.
Transfer Mechanisms: For transfers of personal data from the EU/UK to the US, we rely on:
- Your explicit consent (provided when you submit forms)
- Standard Contractual Clauses (SCCs) where applicable with our service providers
You may contact us for more information about the specific safeguards we have in place for international data transfers.
9. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:
| Data Type | Retention Period | Rationale |
|---|---|---|
| Membership data | Duration of membership + 3 years | Maintain relationship, comply with legal obligations |
| Newsletter subscribers | Until unsubscribe + 30 days | Allow time to process unsubscribe request |
| Donation records | 7 years | IRS tax record requirements for 501(c)(3) |
| Contact form submissions | 2 years | Follow-up and relationship building |
| Analytics data | 26 months | Website improvement analysis |
| Consent records | Duration of consent + 5 years | Demonstrate compliance with GDPR |
When data is no longer needed, it is securely deleted or anonymized.
10. Your Rights
Depending on your location, you have the following rights regarding your personal data:
Right to Access (GDPR Art. 15)
Request a copy of all personal data we hold about you.
Right to Rectification (GDPR Art. 16)
Request correction of inaccurate or incomplete data.
Right to Erasure (GDPR Art. 17)
Request deletion of your personal data ("right to be forgotten").
Right to Restrict Processing (GDPR Art. 18)
Request that we limit how we use your data.
Right to Data Portability (GDPR Art. 20)
Request your data in a structured, machine-readable format.
Right to Object (GDPR Art. 21)
Object to processing based on legitimate interests or for direct marketing.
Right to Withdraw Consent (GDPR Art. 7)
Withdraw consent at any time where processing is based on consent.
Right to Lodge a Complaint
Complain to a supervisory authority if you believe we've violated your rights.
To Exercise Your Rights:
Email info@blackveteransproject.org with:
- Subject line: "Data Request - [Your Request Type]" (e.g., "Data Request - Access" or "Data Request - Deletion")
- Your name and email address so we can locate your records
- What you're requesting: access, correction, deletion, data export, etc.
- Any relevant details to help us process your request
Response time: We'll acknowledge your request within 7 days and provide a full response within 30 days. No account or portal needed—just send us an email.
California Residents: Under CCPA/CPRA, you also have the right to know what personal information we've collected, request deletion, and opt out of "sales" of personal information (we do not sell your data).
11. Withdrawing Consent
Where we process your data based on consent, you have the right to withdraw that consent at any time. Here's how:
- Cookie Consent: Click "Cookie Settings" in the website footer to change your preferences.
- Newsletter/Email: Click "Unsubscribe" at the bottom of any email we send.
- Membership/Form Data: Email info@blackveteransproject.org with "Withdraw Consent" in the subject line.
Note: Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal. Some data may need to be retained for legal compliance (e.g., donation records for tax purposes).
12. Right to Complain
If you believe we have not handled your personal data properly, you have the right to lodge a complaint with a supervisory authority:
European Union
Contact your local Data Protection Authority or visit the European Data Protection Board for a list of EU supervisory authorities.
United Kingdom
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: +44 303 123 1113
California (USA)
California Attorney General
Office of the Attorney General, 1300 I Street, Sacramento, CA 95814
We encourage you to contact us first at info@blackveteransproject.org so we can try to resolve your concern directly.
13. Required vs Optional Data
When you interact with us, some information is required and some is optional:
- Required fields (marked with *) are necessary to provide the service you're requesting (e.g., email for newsletter signup).
- Optional fields help us better serve you but are not required.
You are not legally or contractually obligated to provide personal data. However, if you do not provide required information, we may not be able to provide certain services (e.g., membership registration without an email address).
14. Automated Decision-Making
We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on you. All significant decisions about your membership or participation in our programs are made by humans.
15. Children's Privacy
Our website and services are not directed at children under the age of 16 (or 13 in jurisdictions where COPPA applies). We do not knowingly collect personal data from children.
Age Requirements:
- European Union (GDPR): We do not knowingly process data of individuals under 16 years of age
- United States (COPPA): We do not knowingly collect data from children under 13
- United Kingdom: We do not knowingly process data of individuals under 13 years of age
If we learn that we have inadvertently collected personal data from a child under the applicable age, we will take steps to delete that information as quickly as possible.
If you are a parent or guardian and believe your child has provided us with personal data, please contact us at info@blackveteransproject.org so we can take appropriate action.
17. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes:
- We will update the "Last updated" date at the top of this page
- We will update the version number
- For significant changes, we may notify you by email or website notice
- Where required by law, we will obtain your consent to material changes
We encourage you to review this policy periodically.
18. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices:
Black Veterans Project
Email: info@blackveteransproject.org
General Inquiries: info@blackveteransproject.org