Privacy Policy

    Last updated: July 4, 2026
    Effective date: September 26, 2025

    1. Organization Information

    The Trumpsonian is a project of The Institute for Primary Facts, a nonprofit corporation organized in Washington, D.C. We are the data controller for the personal information processed through our website and services.

    The Institute for Primary Facts
    600 Pennsylvania Ave SE Unit 15180
    Washington, DC 20003
    Email: info@primary-facts.org
    Phone: +1 202-455-0575
    Website: primary-facts.org

    501(c)(3) Status: The Institute for Primary Facts is a nonprofit corporation organized in Washington, D.C., and is recognized by the IRS as a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code. Donations to TIPF are tax deductible to the fullest extent permitted by law.

    2. Information We Collect

    Personal Information You Provide

    • Email Newsletter: Email address
    • Donation Interest: Name, email address, phone number (optional), country code, communication preferences
    • Contact Forms: Name, email address, organization (optional), message content
    • Partnership Inquiries: Name, email, organization, partnership type, message content

    Automatically Collected Information

    • Analytics Data: Page views, session duration, browser type, device information, geographic location (city/country level)
    • Technical Data: IP address, cookies, session identifiers, user preferences
    • Usage Data: Pages visited, time spent, interaction patterns, referral sources

    3. Legal Basis for Processing (GDPR)

    Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal bases:

    • Consent: Newsletter subscriptions, marketing communications, non-essential cookies
    • Legitimate Interests: Website analytics, improving user experience, security monitoring
    • Contract Performance: Processing donation interests, responding to inquiries
    • Legal Compliance: Tax obligations, anti-fraud measures, legal record keeping

    4. How We Use Your Information

    Primary Uses

    • Send newsletter updates and museum announcements
    • Process donation interest submissions and notify you when donations become available
    • Respond to media inquiries and partnership requests
    • Provide customer support and technical assistance
    • Improve our website functionality and user experience

    Analytics and Marketing

    • Analyze website traffic and user behavior to improve our services
    • Send promotional emails to subscribers (you can unsubscribe at any time)
    • Create aggregated statistics and reports (anonymized data only)

    We will never sell, rent, or share your personal information with third parties for their marketing purposes.

    We do not share SMS opt-in data or consent with third parties for marketing purposes. Phone numbers and the fact that you opted in to text messages stay with us and the SMTP2GO SMS gateway that delivers the messages.

    5. Third-Party Services and Data Sharing

    Service Providers

    • SendGrid (Twilio Inc.): Email delivery service for newsletters and notifications - data processed in the US under EU-US Data Privacy Framework and Standard Contractual Clauses
    • Google Analytics: Website analytics (only active with your consent) - data processed globally by Google under Standard Contractual Clauses and their privacy policy
    • Replit: Website hosting platform - data processed under their terms of service
    • In-Memory Storage: User session data temporarily stored in application memory for website functionality

    All third-party services are carefully selected and required to maintain appropriate data protection standards. Data transfers to non-EU countries are protected by adequacy decisions or standard contractual clauses approved by the European Commission.

    6. Your Rights Under GDPR

    As a data subject under GDPR, you have the following rights:

    Right of Access

    Request a copy of your personal data we hold

    Right to Rectification

    Correct inaccurate or incomplete data

    Right to Erasure

    Request deletion of your personal data

    Right to Object

    Object to processing based on legitimate interests

    Right to Restriction

    Limit how we use your data

    Right to Portability

    Receive your data in a portable format

    Right to Withdraw Consent

    Withdraw consent at any time

    Right to Complain

    Lodge a complaint with a supervisory authority

    To exercise these rights, contact us at info@primary-facts.org. We will respond within 30 days.

    7. Cookies and Tracking

    Essential Cookies

    We use essential cookies to make our website function properly, including session management, user preferences (like sidebar state), and security features. These cannot be disabled.

    Analytics Cookies

    Google Analytics cookies are only activated with your explicit consent. When enabled, this data is anonymized and used solely for improving user experience. You can change your cookie preferences at any time through our cookie preference center or opt out via Google's opt-out browser add-on.

    8. Data Retention

    • Newsletter Subscriptions: Until you unsubscribe or 3 years of inactivity
    • Donation Interests: 2 years from submission date or until donation processing begins
    • Contact Form Submissions: 2 years for business correspondence
    • Analytics Data: 26 months (Google Analytics standard retention, only if consented)
    • Session Data: Cleared when you close your browser or after 24 hours of inactivity

    9. Data Security

    We implement appropriate technical and organizational security measures to protect your personal data:

    • HTTPS encryption for all data transmission
    • Secure cloud infrastructure with access controls
    • Regular security updates and monitoring
    • Limited access to personal data on a need-to-know basis
    • Data backup and recovery procedures

    10. Data Processing Location

    As a U.S.-based organization, we primarily process data within the United States. Our service providers may process data in various locations globally, but we ensure adequate protection through:

    • Contractual data protection requirements with all service providers
    • Standard Contractual Clauses (SCCs) for international transfers
    • Compliance with applicable U.S. federal and state privacy laws
    • Security certifications and industry best practices

    11. Children's Privacy

    Our services are intended for audiences aged 16 and older. We do not knowingly collect personal information from children under 16 (or under 13 in jurisdictions where applicable). If we become aware that we have collected such information, we will delete it promptly.

    12. Changes to This Privacy Policy

    We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by email (if you have subscribed) and by posting an updated version on our website with a revised effective date.

    13. Contact Information and Complaints

    Contact Us

    For any privacy-related questions, requests, or concerns:
    The Institute for Primary Facts
    600 Pennsylvania Ave SE Unit 15180
    Washington, DC 20003
    Email: info@primary-facts.org
    Phone: +1 202-455-0575
    Response Time: We aim to respond within 30 days

    Regulatory Authorities

    If you have concerns about how we handle your personal information, you may contact:
    Federal Trade Commission (FTC)
    600 Pennsylvania Avenue, NW, Washington, DC 20580
    Website: www.ftc.gov

    You may also have rights under your state's privacy laws (such as the California Consumer Privacy Act) and may contact your state's Attorney General office.