Last Updated Date: November 6, 2020
What are We Collecting?
When you use our Sites, we may collect various types of information, including your Personal Information. When we use the term “Personal Information” we mean any information relating directly or indirectly to an identified or identifiable natural person. The types of Personal Information we may collect from you depends on the features, services and Sites you use. Here are the types of information we collect and the manners in which it may be collected on the Sites:
- Account Information. If you elect to become a registered user of the Sites, we may collect your first and last name, title, mailing address, job function, market area, your email address, information regarding your employer, as well as your phone number(s) and/or photograph (if provided).
- Location Information. We may also collect your location if you choose to allow us to track your location through our Sites or if your device indicates a certain geographic location. This information may help us provide recommendations based on your location, serve you with advertisements or direct you to a product or service that we believe may be of interest to you and that is marketed to people near your location.
- Device Information. We may collect an identification number unique to your device when you interact with the Sites using a mobile device and we also collect your IP address and other information regarding your mobile device or computer. This could include things such as the features you use, the web pages you visit, and the search terms you enter. This could also include data about your devices and the network you use to connect to our services, including IP address, device identifiers, and data about the performance of the services you use on the Sites and any problems you experience with them. You understand and agree that you will be charged standard data rates by your wireless carrier for all interactions with the Sites using a mobile device.
While you’re under no obligation to provide the information requested, if you decline to do so, we may be unable to provide you with certain services.
How are We Collecting?
We collect and store the Personal Information that you provide to us, including in the methods provided above. For instance, if you sign up on a Site, participate in a survey, or contact us with a question, we may store your communications, including any Personal Information you include in them, so we can effectively respond to you. We may also collect information using various technologies on our Sites while you are visiting or interacting with the Sites. We call this “passive” collection because you may not know or see that this information is being collected. Here are some examples of information that is collected passively via the Sites and a description of how this information is used:
- Internet Protocol (IP) address. Your IP address is a number that lets computers attached to the Internet know where to send you data – such as the webpages you view. We use this information to deliver our webpages to you upon request, to tailor our Sites to the interests of our users and to measure traffic within our Sites.
- Web Beacons (also known as “clear gifs,” “web bugs” or “pixel tags”). “Web Beacons” are tiny graphics with a unique identifier, similar in function to cookies, and are used to allow us to count users who have visited certain pages of the Sites and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, web beacons can tell the sender whether and when an email has been opened. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on web pages.
COOKIES AND SIMILAR TECHNOLOGIES
We use, and allow certain third parties to use, cookies and other similar technologies to provide our services and to help collect data. We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which we explain below:
- Essential. Some cookies are essential in order to enable you to move around our Sites and use their features, such as accessing secure areas of the Sites. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
- Browsing and Functionality. These cookies allow us to remember choices you make on the Sites, such as your preferred language and the country from which you are visiting, and provide enhanced, more personalized features.
There are several ways to manage cookies. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. Please note, however, that by blocking or deleting cookies which are “strictly necessary,” you may not be able to access certain features of our Sites.
In the US, the Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.
USE OF INFORMATION COLLECTED VIA THE SITES
We use your Personal Information that is collected on these Sites primarily for the following purposes:
- To provide you with updates and other information from and about the Program.
- To try to ensure the Sites are relevant to your needs.
- To help us create and publish content most relevant to you.
- To provide you with important notices.
- To manage our relationship through the Sites, allow you access to limited entry areas of the Sites, verify access to accounts, and handle other visitor and member support inquiries.
- To contact you in response to proposals or inquiries that you submit on the Sites.
- To generate web analytics and compile user information for marketing purposes, advertising, conducting marketing analysis, providing you with recommendations for products or services based on your profile, and promotional material planning and distribution.
- To comply with applicable laws or legal process and/or respond to requests from public and government authorities.
“Non-Personal Information,” by which we mean any information that cannot be used to identify you personally, is used similarly as described above and in other ways as permitted by applicable laws, including combining Non-Personal Information with Personal Information. If Personal Information is combined with Non-Personal Information, it will be treated as Personal Information. Please note that over time Non-Personal Information may become Personal Information due to regulatory developments, technological advancements, or the co-mingling of Personal and Non-Personal Information.
LEGAL BASES FOR PROCESSING
We process Personal Information in accordance with applicable law and with transparency and fairness. The legal bases for the processing activities listed in the section above are as follows:
- For numbers 1 through 6, in order to fulfill our contractual obligations to you;
- For number 7, with your consent; and
- For number 8, in compliance with the law.
SHARING AND DISCLOSURE OF INFORMATION
We may share or disclose your Personal Information to the following parties and in the following instances:
- To fulfill a service to you. For example, if you choose to attend an event or request information, we may share your Personal Information in order to provide the program to you. In addition, if you contact us with a question, we may use your email address or mobile phone number to process your request and respond to your question. Also, if you are entering a sweepstakes or contest, we may use your Personal Information in order to fulfill the terms of that promotion. This means that we may share the information for prize fulfillment purposes with mail carriers. We also may share your information with the co-sponsor and/or promotional partners of that promotion.
- To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your Personal Information for research, administrative and/or internal business purposes. These parties may use your Personal Information to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes.
- To unaffiliated third-party service providers, agents, independent contractors who help us maintain our Sites and provide other administrative services to us (including, but not limited to, processing your requests, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We have agreements in place to require third parties not to use the Personal Information for any other purpose than to provide the administrative services for which they are responsible.
- To complete your purchase. If you choose to make a purchase on the Sites, we may collect from you your credit card number, billing address and other information related to such purchase, and we may use such collected information in order to fulfill your purchase. We may also provide such information, or other Personal Information provided by you, to unaffiliated third parties as necessary to complete your purchase (for example, to process your credit card).
- To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of the Program and the Sites or act in urgent circumstances to protect the personal safety of our end users.
- To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
- To track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
- To protect against potential fraud, we may verify with third parties the information collected from the Sites. In the course of such verification, we may receive Personal Information about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us, and that the card has not been reported as lost or stolen.
do not otherwise use, share or otherwise disclose your Personal Information to any third
COLLECTION AND USE OF INFORMATION FROM CHILDREN
The Sites are not intended for use by children. The Program does not knowingly collect information from children under the age of 18. If we discover that we have received information from a child under the age of 18, we will delete it.
INTERNATIONAL TRANSFER OF INFORMATION
If you choose to provide us with Personal Information, we may transfer that information to its affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union (EU) or other regions with laws governing data collection and use that may differ from US law, please note that you are transferring your Personal Information to the United States which does not have the same data protection laws as the EU and may provide more limited recourse mechanisms, including dissimilar or, at times, weaker data protection rights. Where necessary, we utilize Standard Contractual Clauses approved by the European Commission to legitimize the transfer of Personal Information from the EU to the United States and other countries. With knowledge of these risks, by providing your Personal Information you acknowledge that you understand:
- Your Personal Information will be transferred to the United States as indicated above.
RIGHTS AND CHOICES
Additionally, residents of the European Union, the EEA, the United Kingdom, and Switzerland have the following additional rights covered in the below section, “Personal Information in the European Union, the EEA, the United Kingdom, and Switzerland.”
PERSONAL INFORMATION IN THE EUROPEAN UNION, THE EEA, THE UNITED KINGDOM, AND SWITZERLAND
We only collect and use Personal Information processed in the European Union, the EEA, the UK and Switzerland when we have a lawful basis as follows:
- To perform our duty in a contract with you: for example, when you work for us as a service provider, we will need to process your Personal Information for your services agreement. If you are an exhibitor we will use your Personal Information to fulfil our duty in the contract that we have with you.
- For a legal obligation: for example to comply with the law or respond to legal process or lawful requests, including from law enforcement and government agencies.
Consent: We will rely on your consent to use your Personal Information for marketing purposes in accordance with applicable law.
RIGHT OF ACCESS
You have the right to get confirmation about whether or not your Personal Information is being processed. Where that is the case, you have the right to access the Personal Information and other information, such as the purposes, the categories of Personal Information, the recipients (or categories of recipients) to whom the Personal Information have been or will be disclosed, in particular recipients in third countries or international organizations, where possible, the predicted period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period, your rights, etc.
Where feasible and permitted by law, we will provide a copy of the Personal Information we are processing. For any further copies requested, we may charge a reasonable fee based on administrative costs. If you make the request by electronic means, and unless otherwise requested, the information shall be provided in electronic form.
RIGHT TO RECTIFICATION
You have the right to rectify or complete your Personal Information if inaccurate or incomplete.
RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”)
You shall have the right to the erasure of your Personal Information in certain circumstances, such as:
- the Personal Information is no longer necessary for the purposes for which they were processed
- you withdraw your consent on which the processing is based, and we have no other legal ground for the processing
- you object to the processing
- your Personal Information has been unlawfully processed
This right shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information
- for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject
- for the performance of a task carried out in the public interest
- for reasons of public interest in the area of public health
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
- for the establishment, exercise or defense of our legal claims
RIGHT TO RESTRICTION OF PROCESSING
You shall have the right to restrict the processing if:
- you contest the accuracy of your Personal Information, for a period enabling us to verify the accuracy of the Personal Information
- the processing is unlawful and you oppose the erasure of the Personal Information and request the restriction of their use instead
- we no longer need the Personal Information for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims
- you exercised your right to object to processing pending the verification whether our legitimate grounds override yours
RIGHT TO DATA PORTABILITY
You have the right to receive your Personal Information that you have given us, in a structured, commonly used and machine-readable format. You have the right to send that Personal Information to another controller, if the processing is based on consent pursuant or on a contract and is carried out by automated means.
RIGHT TO OBJECT
You have the right to object, on grounds relating to your particular situation, to processing of your Personal Information you have made public or is necessary for the establishment, exercise or defense of legal claims, including profiling based on those provisions. We will stop processing the Personal Information unless we have compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
If Personal Information is processed for direct marketing purposes, including profiling, you may object at any time.
You may exercise your right to object by automated means using technical specifications.
AUTOMATED INDIVIDUAL DECISION-MAKING, INCLUDING PROFILING
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you. This excludes special circumstances. For example, when it is necessary for entering into, or performance of, a contract between the data subject and a data controller, is based on the data subject’s explicit consent, etc.).
RIGHT TO WITHDRAW CONSENT
Where the processing of Personal Information is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.
RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
You have the right to lodge a complaint with a supervisory authority.
We communicate with users who subscribe to our services on a regular basis via email. For example, we may use your email address to send you information about a service requested by you, to confirm a service requested by you, to send you notices regarding important information and meetings, to send you information about changes to our services, and to send notices and other disclosures as required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional.
However, we provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communication from us, such as emails or updates from us regarding new services and products offered on the Sites or if you do not want us to share your Personal Information with third parties. The opt-out choice may be exercised by ticking or un-ticking the appropriate box if such checkbox is available at the points where Personal Information is collected, or by contacting us. We will process your unsubscribe request as soon as possible and in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe request is processed. You also may opt-out of receiving such emails by clicking on the “unsubscribe” link within the text of the email.
FORUMS, CHAT ROOMS & OTHER PUBLIC POSTING AREAS
Please note that any information you include in a message you post to any chat room, forum or other public posting area is available to anyone with Internet access. If you don’t want people to know your email address, for example, don’t include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.
THIRD PARTY WEBSITES
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the Personal and Non-Personal Information collected via the Sites.
SECURITY AND RETENTION
We implement reasonable security measures to protect against the loss, misuse, or alteration of the information you provide us. We may use third party products and services to secure or store your information. Please understand that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to the Program is done at your own risk. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing Personal Information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Notice shall be sent to:
- The Program, at: firstname.lastname@example.org. You, at the contact information on file with the Program
Both you and the Program agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party. IF ANY DISPUTE CANNOT BE RESOLVED BY THE ABOVE DISPUTE RESOLUTION PROCEDURE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR SUCH DISPUTE WILL BE DECIDED BY BINDING ARBITRATION ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY. Other rights that you and we would have in court will not be available or will be more limited in arbitration, including discovery and appeal rights. Any such Dispute shall be exclusively submitted to JAMS (www.jamsadr.com) for binding arbitration under its rules then in effect, and will occur in the Washington, DC area, before one arbitrator to be mutually agreed upon by both parties.
CHOICE OF LAW
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding the Program’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at the address provided below and reference “Shine the Light Request.”
DO NOT TRACK DISCLOSURE
The “Do Not Track” (DNT) privacy preference is an option that may be made in your web browser allowing you to opt out of tracking by websites and online services. Because there is not yet an accepted standard for how to respond to a DNT signal, we do not currently respond to DNT signals on our Sites or on websites where we provide advertisements, content, or other services.