Last Updated and Effective as of: July 1, 2019
We may collect and maintain Personal Information about you when you voluntarily provide it to us. For example, you may choose to provide us with such information when you complete an online form, contact us, sign up for our newsletter, create an account or become a member of the IoTC. This information may include your name, email address, physical address, phone number, occupation, employer, payment information, or other similar personally identifiable information about you (“Personal Information”). Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with membership benefits).
When you visit or use the Website, we may automatically collect certain non-personally identifying information about you, such as the type of browser or device operating system you use, the domain name of the website from which you linked to us, the amount of time you spend on the Website, the pages on the Website that you view, clickstream data, and other log file data and may aggregate information in a manner which does not identify any individual. We may also aggregate information collected from our users (such as the number of users in a particular region or having particular characteristics). To be clear, some of this information (including for example your IP addresses and certain unique device identifiers), may identify a particular computer or device, and may be defined as “Personal Data” in some jurisdictions including in the European Union (“EU”).
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “EU DATA SUBJECT RIGHTS AND DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
Information Usage, Disclosure and Recipients: Subject to the section titled “EU Data Subject Rights and Disclosures”, we may use and disclose your information, which may include your Personal Information, as described herein:
- We will use Personal Information to operate the Website and to provide you with any specific services that you have requested.
- We may share your business contact information with sponsors of our events for their direct marketing purposes. If you would like to opt-out of such disclosures please see the Opt-Out section below.
- We may use your Personal Information to respond to your direct inquires.
- We will use your Personal Information to add you to our mailing lists and to send you emails from time to time.
- We may permit our vendors and subcontractors (such as our payment processors, email service provider, or host providers) to access your Personal Information, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.
- We may disclose Personal Information as required by law or legal process.
- We may disclose Personal Information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Website.
- We may transfer your Personal Information in connection with a bankruptcy proceeding or the sale, merger or change of control of IoTC or the division responsible for the services with which your Personal Information is associated.
Please note that if you specifically consent to additional uses of your Personal Information, we may use your Personal Information in a manner consistent with that consent. Aggregate information may be shared with any number of parties, provided that such information shall not specifically identify you.
We may also use and place cookies on your device from our third party service providers in connection with the Website, such as an analytics provider that helps us manage and analyze Website usage. An example of such third party is Google Analytics, which we use to collect and analyze demographic and other information, and through which Google will collect certain information to be used according to Google’s privacy practices. To opt-out of the use of Google Analytics, click here.
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Google Analytics - Website performance measurement
Security and Data Retention: We have undertaken and will continue to undertake commercially reasonable efforts designed to prevent unauthorized access to user data retained in our servers. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties. We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
Other Websites, Apps and Services: As a convenience to you, we may provide links to third party websites, apps or services from within the Website. We are not responsible for the privacy practices or content of these third party sites, and by providing a link we are not endorsing or promoting such third party websites. When you link away from our Website, you do so at your own risk. We encourage you to read the policies and terms of every website, app or service you visit.
Social Networking Services: The Website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your Personal Information, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.
Information Relating to Children: We do not knowingly collect Personal Information from anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.
As noted above, you may opt-out of or restrict the placement of cookies on your device or remove them from your browser by adjusting your web browser preferences. To opt-out of the use of Google Analytics, click here. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve Personal Information from your device without your knowledge.
Do Not Track: Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.
California Privacy: Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at the address set forth below. If you do not want your Personal Information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at the email address set forth below.
Updating or Changing Your Personal Information: We understand that your Personal Information can change over time, including when you move or change your phone number. If you would like to notify us of any changes to your Personal Information, please contact us at as set forth below. You may also request access to your Personal Information (if you have provided such information to us through the Website) and information about our collection, use and disclosure of Personal Information by using the contact information provided above. Unless prohibited by law or legal process, you will be given reasonable access to your Personal Information, entitlement to challenge the accuracy and completeness of the information, and the ability to have it amended as appropriate.
EU Data Subject Rights and Disclosures: This section applies to you if you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”):
Legal Basis for Using Your Personal Information
We rely on the following legal bases to process your Personal Data:
- It may be necessary for us to use and disclose your Personal Data for the performance and fulfillment of the contract between us and to provide you with our services;
- We may use and disclose your Personal Data where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
- As noted above, if you specifically consent to certain uses of your Personal Data, we may use your Personal Data in a manner consistent with that consent; and
- We will also process, transfer, disclose and preserve Personal Data when we have a good faith belief that doing so is necessary including to comply with a legal or regulatory obligation.
Rights of EU Data Subjects
Subject to local law, you may also have certain rights regarding information that we have collected and that is related to you. You have the right to withdraw previously provided consent for our processing of your Personal Data. Such individuals also have the following rights under certain circumstances:
- Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being processed and provides access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data has been or will be disclosed and the purposes of the processing.
- Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.
- Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
- Right to be forgotten – This right is also known as the “right to erasure.” It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
- Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
- Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
To exercise your rights, please contact us at email@example.com.
Right to Complain to a Supervisory Authority
If you are located in the European Union with rights under the GDPR and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us at the address below in the first instance and we will do our very best to resolve your concerns.
Use of your Personal Data for Marketing Purposes
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising:
- Promotional messages from us: You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will get your express opt-in consent before we share your Personal Data with any company outside our company for marketing purposes.
Cross border transfers: By using the Website, you authorize the export of your information to the USA and its storage and use as specified in this policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA. We may transfer personal data from the European Economic Area and Switzerland to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. We may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EU For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.