PLEASE READ THIS PRIVACY POLICY ( “PRIVACY POLICY,” “POLICY” OR BY IMPLICATION) CAREFULLY BEFORE ACCESSING OR PARTICIPATING IN ANY MANNER, INCLUDING WITHOUT LIMITATION, IN ANY WEBSITE(S), SITE(S) OR PAGE(S) THEREOF, NEWSGROUP, WEBLOG (BLOG), ONLINE PUBLICATION, BULLETIN BOARD, CHATROOM, MAILING LIST, TRANSACTION, OR OTHER ONLINE FORUM OR CONTENT DISSEMINATION WHATSOEVER MADE AVAILABLE AT OR FROM OUR WEBSITE(S), ANY CORPORATE OR PERSONAL ENTITIES OWNING, CONTROLLING OR MAINTAINING THE SAME, OR ANY AFFILIATED ENTITIES OR INDIVIDUALS THEREOF (COLLECTIVELY “SITE(S) ,” “WE,” “US,” OR “OUR,” AS THE CASE MAY BE).
I. PRIVACY POLICY PART 1: GENERAL TERMS AND CONDITIONS
(1) ONLINE PRIVACY NOTICE AND CONDITIONS
This Privacy Policy explains how WE collect, uses, shares and safeguards Personal Information (defined below) and Nonpersonal Information (defined below) on OUR Sites, including mobile applications, OUR profiles on OUR social media sites and any other digital services and platforms officially operated or used by US from time to time, as well as by phone or by paper.
(2) PERSONAL AND NONPERSONAL INFORMATION WE COLLECT AND PROCESS
(a) Personal Information: WE may collect information (whether online, by phone, or by paper) that enables US to identify or contact you (“Personal Information”) to carry out its business purposes. OUR Sites may collect this information for a variety of business reasons, including but not limited to, applying for membership, or as a client or customer, or registering for OUR events or programs, purchasing OUR services or products, or otherwise interacting with US or OUR affiliated entities, business partners, vendors or suppliers. The types of Personal Information we collect include but are not limited to: (i) General data collected from individuals or entities, including members, clients and/or customers. Examples include names, home and business addresses, email addresses, dates of birth, Internet protocol (IP) and website addresses and phone numbers, whether mobile/landline and conducted for business/personal use; (ii) Professional data, such as for example, information about an individual’s professional occupation, background, place of work and colleagues; (iii) Government-issued identification numbers, such as, for example, social security numbers, national identification numbers and tax identification numbers; (iv) Financial information, such as for example, credit and debit card numbers, PayPal information, credit reports, passwords and PIN numbers, for service/product sales or employment purposes; (v) Sensitive Personal Information, such as, for example, racial or ethnic origin, sexual orientation and disability information, for diversity or accessibility purposes; and (iv) Other identification information, such as, for example, photographs or uploaded personal data. Please note that if you are located in the European Economic Area (EEA), Personal Information herein includes all Personal Data as defined under relevant EEA laws. (See below) Finally, note that WE may also receive personal information from third parties for OUR use in marketing to potential new members, clients or customers.
(b) Nonpersonal Information: WE may also collect information that does not directly identify you or information particular to you as you interact with our Sites (“Nonpersonal Information”). This information may also be collected via multiple mediums, such as, for example, online, via secure connections, by email, by phone or by paper. The types of Nonpersonal Information we collect includes, but is not limited to: (i) your industry and business, such as, for example, company size and location, job functions and seniority levels; (ii) your usage of the Sites, such as, for example, browsing history, search terms, number of clicks, referring/exit pages, date/time stamp and time on the Site; (iii) the services and/or products you have viewed, including advertisements and marketing literature related to the same; (iv) your computer type, operating system and platform type; and (iv) your Internet service provider (ISP).
(3) PROTECTING YOUR PERSONAL INFORMATION
WE implement commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of information. Except for membership directories, membership lists and registration lists, and the sharing of information as set forth in this Privacy Policy, we restrict access to Personal Information to certain companies who need the information to operate, develop, or improve our services. These individuals or partner organizations are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. Please note that unfortunately, no data transmission over the Internet or electronic storage is fully secure. Accordingly, and despite our reasonable efforts to protect your Personal Information from unauthorized access, use, or disclosure, WE cannot guarantee or warrant the security of the Personal Information you transmit to us, or to or from our online Sites. If you have questions about this Privacy Policy, please contact us at our Support pages.
(4) USE OF YOUR INFORMATION
In addition to the uses described above, we use your Personal Information, sometimes combined with Nonpersonal Information, in a variety of ways including, but not limited to the following.
(a) Personal Information: (i) Identify you when you visit our Sites; (ii) Provide service communications such as bill reminders, order confirmations, program registrations and member/client/customer service messages; (iii) Provide products, information and services you request or that we think you may be interested in; (iv) Respond to your emails or online requests for products, services, or information; (iv) Deliver and process surveys; (v) Personalize and improve the usability of the Sites; (vi) Fulfill and/or deliver OUR products and services; (vii) Tailor content, advertising and marketing to you; (viii) Publish membership/client/customer directories, membership/client/customer lists and registration lists on the Sites and in print and digital media to allow members/clients/customers and the public to find you; such directories and lists will not include credit card information or personal identification numbers such as social security numbers.
(b) Nonpersonal Information: We use Nonpersonal Information to improve the usability of our Sites and for other business reasons. We or other third-party companies also use the Nonpersonal Information to provide content and targeted advertisements to you (ads based on the Nonpersonal Information). We may provide Personal Information to third parties with whom we share your Nonpersonal Information. Please note that, when you select an advertising link or other link that takes you to sites not operated by US, you may be subject to the privacy policies of these third-party sites.
(5) COOKIES AND OTHER WEB DEVICES
Our website sends cookies (e.g., pieces of code or text placed on your computer by us or third-parties when you browse our Sites) to your web browser (if your browser’s preferences allow it) to collect data when you browse our Sites. Cookie settings can be controlled in your Internet browser to automatically reject some forms of cookies. If you view our website without changing your cookie settings, you are indicating your consent to receive all cookies from our Sites. If you do not allow cookies, some features and functionality of our Sites may not operate as expected. In addition to cookies, we place technological tools (and allow certain third parties to place technological tools) such as tags and beacons (e.g., code scripts that are primarily used to track visitors’ activities on our Sites by web analytics software), Internet Protocol (IP) addresses, and other tools, to collect your data for the purposes listed in this Privacy Policy.
(6) LINKING TO OTHER INTERNET SITES
Please be advised that other Internet sites that are linked from the Sites or from OUR emails may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy policies/statements of these other linked sites, applications, or other digital platforms.
(7) OPTING OUT AND HOW YOU WOULD MANAGE YOUR DATA PROCESSING
You can manage your profile and email preferences, including “opting out” of email by contacting us using the information in the “Contact Information” section below. If you prefer to receive hard copy mailings only from US, you can contact us at our Support pages and request to have your name and address removed from the list we provide to third parties. For California residents, please consult the “California Privacy Rights” section for additional considerations. Our processing of your data is based upon your consent, contract performance (e.g., your purchase of products or membership/client/customer sign-up/renewal), legitimate business interest (e.g., direct marketing of goods and services), or compliance with law. You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.
(8) SHARING OF YOUR DATA
We may share your Personal Information, sometimes combined with Nonpersonal Information, in a variety of ways including, but not limited to the following.
(a) Service requests and business-related functions: We may share information with third parties to fulfill service requests and to perform business functions. For instance, WE may have contracts with third parties in order to provide services on our Sites, such as data hosting services; member/client/customer support and consulting related services; packaging, mailing and delivery related services; and registration for events and related services.
(b) As required by law and reasonably necessary: We may share information with third parties as reasonably required by law or to protect US in the good-faith belief that such action is necessary in order to: (i) conform to legal requirements or comply with legal process served on us; (ii) protect and defend our rights or property; or (iii) protect the personal safety of our personnel or members of the public in appropriate circumstances.
(c) Sale, Transfer or Other Actions Involving Assets We may share information with third parties if WE and/or our assets, or a portion of thereof, are sold, assigned, transferred, or merged, or if WE undergoes some other relevant change, including a change to its corporate form as part of a bankruptcy proceeding or otherwise; here, the information may be transferred as part of that transaction or change.
(d) For Offering Products/Services: We may share your information with third parties to offer products and services that may be of interest to you or our other members/clients/customers professionally or personally, such as, for example, business software solutions or product discounts. Users can request their information to be removed from such lists by contacting us, as set forth in the “Contact Information” section below.
(e) Email addresses: Sharing of information with third parties.
Sharing of your email address, but only as permitted by OUR email policy, which is as follows:
(i) Your email address may be used by US, our entities, affiliates, subsidiaries, sponsors and vendors (“OUR Email Users”) in performing services for our members, clients or customers, or offering products or services on behalf of US, or as otherwise required to provide our products and services;
(ii) WE do not sell or rent email addresses to any outside parties;
(iii) OUR Email Users may also share your email address with third parties to enable the same to take security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of information.
(iv) OUR Email Users may also share email addresses with third parties as necessary for performing certain services on our behalf, such as packaging, mailing and delivering products or services, processing of event registrations, and responding to your service requests.
(f) Please be advised, however, that in certain of the above cases, your email address may be visible to others who have interest in OUR Email Users’ products, services or events, as well as the public, through OUR Email Users’ membership directories, membership lists and registration lists and the like.
(9) USER ID AND PASSWORD
Please note that certain areas of the Sites require the use of a user ID, email address, or password as an additional security measure that helps protect your Personal Information. To help you protect your privacy, these Sites have tools to help you log in and log out.
(10) COLLECTING INFORMATION FROM CHILDREN
Please note that we do not knowingly collect Personal Information from or market to children under the age of 13.
(11) ACCESSING, AMENDING AND DELETING OF YOUR PERSONAL INFORMATION
Please note that we rely on you to update and correct your Personal Information with respect to use of the Sites or delivery of products and services. If you are a user of our Sites, subscriber to our publications, purchaser of our products and services, or otherwise a member, client or customer, you can review, update and correct your information directly on OUR Sites or by contacting us at our Support pages. Our policy is to retain your Personal Information for the period reasonably necessary to fulfill the purposes provided in this Privacy Policy or as otherwise made available to Site users. However, a longer retention period may be reasonably required or as otherwise permitted by law. This may include retaining your Personal Information indefinitely, even after you are no longer OUR member, client or customer, in order to provide you with future marketing opportunities and other purposes, as well as to comply with our legal obligations, resolve disputes, or enforce any of our agreements. Please note that you can request, at any time, that we delete your Personal Information. All requests must be directed to the contact information provided hereinbelow. We may also decide to delete your Personal Information if we believe that the information is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other members, clients, customers, individuals, or third parties, or otherwise contrary to our business objectives. When your Personal Information is removed, it will be deleted from our active databases or anonymized so that the information is no longer identified with you, but the information may remain in our archives if WE determine that it is not practical or possible to delete it.
(12) YOUR RIGHTS CONCERNING COMPLAINTS TO RELEVANT AUTHORITY
As you are the subject of the Personal Information, accordingly you have the right to lodge a complaint with a relevant management authority in our organization and externally, in particular, with the relevant authorities of the state of your habitual residence, place of work, or place of the alleged misuse or infringement, if you believe that the processing or management of your Personal Information does not comply with legal requirements.
(13) BREACH NOTIFICATION
In the event we determine the occurrence of a data security incident, we will notify you by email, or via other means lawfully permitted, such as US mail and via telephone.
(14) CALIFORNIA PRIVACY RIGHTS
Please be advised that in addition to the rights as explained in this Privacy Policy, California’s “Shine the Light” law provides that California residents who provide personal information (as defined in the relevant statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. Where applicable, such information includes the categories of personal information and the names and addresses of those entities with which we shared such personal information for the immediately prior calendar year. I.e., a request made in the present year will receive information about the prior year. In order to obtain this information please contact us by writing to us at our office address as provided on our Sites. Kindly include your full name, address and your relevant membership with US, client or customer information and/or affiliation where applicable.
(15) INFORMATION TRANSMITTED TO COUNTRIES OUTSIDE OF THE UNITED STATES
Your Personal Information is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your information. By submitting your Personal Information to us, you agree to the transfer, storage and processing of your Personal Information in the United States.
(16) CANADA ANTI-SPAM LAW
WE comply with the Canada Anti-Spam Law. Any individuals or entities who are not associated with US and who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as the term is defined under the Canada Anti-Spam Law), with the exception of individuals have “opted-in” to receive Commercial Electronic Messages.
(17) RIGHTS OF INDIVIDUALS LOCATED IN THE EUROPEAN ECONOMIC AREA (EEA)
Please note that the EEA General Data Protection Regulation (GDPR) provides certain protections to individuals present in EEA, namely respecting the collection, use, transfer, storing, and other processing of personal data. Please consult our Paragraph II below (“PRIVACY POLICY PART 2: EUROPEAN ECONOMIC AREA (EEA) PRIVACY STATEMENT”) for more information. If you are an individual qualifying as to the foregoing, you will have the following rights in addition to, or by way of supplementation to the rights of this Privacy Policy, with regard to your Personal Data.
(a) You have the right to access the handling of your Personal Information: With respect to Personal Information that we retain, please be advised that you may request details concerning the same. We will confirm whether we are processing your Personal Information and we will disclose supplementary information including the categories of Personal Information, the sources from which it originated, the purpose and legal basis for the processing, the expected retention period, and the safeguards regarding Personal Information transfers to non-EEA countries, subject to the limitations set out in applicable statutes, regulations and other laws.
(b) You have the right to have your Personal Information removed: Please note that we will delete your Personal Information upon your request reasonably promptly if the following conditions apply: (i) the Personal Information was processed illegally; (ii) you withdraw the consent, as noted hereunder, to the processing or retention of your Personal Information; (iii) retention of your Personal Information is no longer necessary; (iv) you object to the processing of your Personal Information and there are no overriding legitimate grounds for such processing; or (v) the Personal Information must be deleted for us to comply with our legal obligations. Please note that we will inform any third parties we might have shared your Personal Information with regarding any deletion requests you submit. Please note however that we will decline your request for deletion if processing of your Personal Information is necessary: (vi) to comply with our reasonably considered legal obligations; (vii) in the pursuit of a legal action; (viii) for the detection and monitoring of fraudulent activities; or (ix) for the performance of a task in the public interest.
(c) You have the right to limit the processing of your Personal Information upon certain conditions: At your request, we will limit the processing of your Personal Information if the following conditions apply: you dispute the accuracy of your Personal Information; your Personal Information was processed unlawfully and you request a limitation on processing, rather than the deletion of your Personal Information; we no longer need to process your Personal Information, but you require your Personal Information in connection with a legal claim; or you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.
(d) You have the right to complain to a higher authority concerning processing and retention of your Personal Information: If you are not satisfied with our response, you have the right to complain to or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction.
(e) You have the right to correction concerning your Personal Information: We will comply with your request to edit and update incorrect Personal Information promptly.
(f) You have the right to object to the processing concerning your Personal Information: Where we process your Personal Information based upon our legitimate interest then you have the right to object to this processing.
(g) You have the right to be notified concerning correction, deletion, and limitation on processing of your Personal Information: To the extent practicable, you will be notified of any correction, deletion, and/or limitation on processing of your Personal Information.
(h) You have the right to withdraw consent you have provided concerning your Personal Information: You have the right to withdraw any consent you may have previously given us at any time. If you withdraw your consent, this will not affect the lawfulness of our collecting, using and sharing of your Personal Information up to the point in time that you withdraw your consent. Even if you withdraw your consent, we may still use your information that has been fully anonymized and does not personally identify you.
(i) You have the right to the portability of your Personal Information: At your request, we will provide you free of charge with your Personal Information in a structured, commonly used and machine readable format, if: (i) you provided us with Personal Information; (ii) the processing of your Personal Information is based on your consent or required for the performance of a contract; or (iii) the processing is carried out by automated means.
(j) You have the right not to be subject to decisions based solely on automated processing of your Personal Information: You will not be subject to decisions with a legal or similarly significant effect (including profiling) that are based solely on the automated processing of your Personal Information, unless you have given us your explicit consent or where they are necessary for a contract with us.
(k) If you wish to contact us concerning exercising of your rights per this section, please email us via our Support pages.
(18) CONTACT INFORMATION
If you have questions, comments, or complaints concerning our privacy practices or if you wish to change, access, or remove your Personal Information, please contact us via our Support pages. We will attempt, where practical, to respond to your requests and to provide you with additional privacy related information.
(19) CHANGES TO THE PRIVACY POLICY
As WE, our corporate personnel, membership, products and services change from time to time, please be advised that this Privacy Policy is expected to change as well. Accordingly, we reserve the right to amend the Privacy Policy at any time and for any reason. The date of the last revision to the Privacy Policy will be indicated or communicate as an effective date of the relevant page(s).
II. PRIVACY POLICY PART 2: EUROPEAN ECONOMIC AREA (EEA) PRIVACY STATEMENT
This European Economic Area (EEA) Privacy Statement discloses information about the privacy practices with respect to personal data protected under the General Data Protection Regulation (GDPR) for the EEA, which became effective on May 25, 2018. The GDPR is a regulation adopted for the EEA that governs the use and processing of personal information. WE are committed to processing your EEA Personal Data in compliance with the GDPR and has prepared this statement to provide you with information about your rights under the GDPR. In addition to this statement, other notices have been published applying to the use and other processing that may be subject to the GDPR of Personal Information (per our Privacy Policy).
The information provided in this statement applies solely to individuals whose data is subject to protection under GDPR, and defined as EEA Personal Data (see below), and the statements hereunder are subject to the terms of our Privacy Policy.
(1) Information associated with our Sites (per our Privacy Policy).
For information associated with OUR Sites, this EEA Privacy Statement should be read together with our Privacy Policy or our Sites that have linked you to this webpage. The Sites are published in the United States and are subject to the laws of the United States. If you are located in the EEA and you voluntarily submit personal information to us, your information will be used as provided in our Privacy Policy and in this EEA Privacy Statement and will be transferred to, and/or stored in, the United States.
(2) Direction to this webpage.
The general information published on this webpage is intended to supplement specific information that you may have already been given in connection with your activities related to US or OUR affiliates.
(3) Meaning of “EEA Personal Data”
(a) Your personal information is EEA Personal Data if: it is “personal data” as defined in the GDPR; and the GDPR includes protection of the personal data in its scope.
(b) The GDPR defines “personal data” broadly. It includes “any information relating to an identified or identifiable natural person.” Examples of personal data include your “name, an identification number, location data, an online identifier [and] factors specific to [your] physical, physiological, genetic, mental, economic, cultural or social identity.” GDPR. Article 4(1).
(c) The scope of the GDPR generally applies to collecting, using or other “processing” (see below) of personal data (as provided in Article 3): (i) when the processing is part of the activities of an organization that acts in an established way in the EEA (it is not required that the processing take place in the EEA); (ii) when the processing is by an organization that is not established in the EEA and the organization offers goods or services to persons who are physically in the EEA. (A payment for the goods or services is not required.); and (iii) when the processing is by an organization that is not established in the EEA and the processing activities are related to the monitoring of the behavior of a person who is physically in the EEA, as far as their behavior takes place within the EEA. For example, if you provide personal information to US when you are physically present in the EEA or while you participate in one of OUR established programs occurring in the EEA, that personal information may be EEA Personal Data.
(d) “Processing” is a term used by the GDPR to cover any way of working with personal data, from collecting to using to sharing to destroying. GDPR Article 4 (2).
(4) Purpose and lawful basis under the GDPR for processing your EEA Personal Data
It is OUR policy to collect, use and process EEA Personal Data about you only where we have a legal basis for doing so under the GDPR. A legal basis under the GDPR may be, for example: (i) we need it to perform a contract with you, such as to provide you services; (ii) it satisfies a legitimate interest (which is not overridden by your data protection interests), such as to promote and provide goods and services to you and to protect our legal rights and interests; (iii) you give us consent to do so for a specific purpose; (iv) we need to process your data to comply with a legal obligation; (v) we need to process your data in connection with your or another person’s vital interest; (vi) we need to process your data in connection with the public interest; (vii) we have another legal basis permitted under the GDPR. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Unless you are told otherwise, there is no requirement to supply us with any of your EEA Personal Data. We may process your EEA Personal Data for a variety of service- and business-related purposes, including for analyzing and improving website performance; email and other communications; processing you have requested; third-party services; and security and legal requirements. The use of your EEA Personal Data in the manner described above and in the Privacy Policy are necessary for our legitimate interests in operating and improving our Sites, analyzing their use, and ensuring their security. The Sites collect certain EEA Personal Data and we use it in ways that are compatible with your individual rights and freedoms. Where you enter your EEA Personal Data into an online form on any of our Sites for any specified purpose, you will be told about the use we will make of that information (e.g., to send you newsletters or to enable your attendance at an event).
(5) How EEA Personal Data is kept.
Information about how long different types of information are retained is provided in our Privacy Policy.
(6) Rights respecting EEA Personal Data
These rights are specified in our Privacy Policy.
(7) Questions
(a) If you have any questions about how your EEA Personal Data is used, or wish to exercise any of your rights with respect to your EEA Personal Data, please contact us (per our Privacy Policy).
(b) If you are unsatisfied with the way your EEA Personal Data is being handled, or with the response received from us, you have the right to lodge a complaint with the GDPR supervisory authority in the EEA country where you habitually reside, where you work, or where you believe an infringement of the GDPR occurred.
(8) Changes to this Privacy Policy
WE and our affiliated entities reserve the right to change, modify, or otherwise amend this Privacy Policy, at our sole discretion and at any time as we deem circumstances warrant. Any such changes will be posted accordingly.
Please also refer to our Terms of Use, which is incorporated herein by reference in its entirety: click here.
