I. WHAT INFORMATION DO WE COLLECT?
A. Personal Information you disclose to us
We collect personal information that you provide to us. We collect information (whether online, by phone, or by paper) that enables the ABI to identify or contact you (“Personal Data”) to carry out its lawful business purposes. ABI Websites collect this information for a variety of business reasons, including but not limited to, applying for membership, registering for an ABI event or program, purchasing ABI products or services, or otherwise interacting with the ABI.
The types of Personal Data we collect include, but are not limited to:
- General data (e.g., names, dates of birth, home and business addresses, email addresses, Internet protocol addresses and mobile/landline business/personal telephone numbers that are provided by our members/customers)
- Professional data (e.g., bar pass date, CLE/CPE identification numbers and state(s))
- Government-issued identification numbers (e.g., social security numbers, national identification numbers and tax identification numbers), for example from employees and independent contractors, but not from members unless the ABI makes payments to members, such as honoraria or royalties for publishing rights
- Other identification information (e.g., photographs)
- Financial information (e.g., credit and debit card numbers, credit reports, passwords and PIN numbers) for product sales or employment purposes
- Sensitive Personal Data (e.g., racial or ethnic origin, sexual orientation and disability data) for diversity or accessibility purposes
- Social Media Login Data. We may provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.
B. Personal information from Third-Parties
The ABI also receives Personal Data from third parties for the ABI’s use in marketing to potential new members, such as lists of other organizations’ conference attendees from various other organizations.
C. Information Automatically collected (Non-personal information)
Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit the site.
We may automatically collect information (whether online, by phone, or by paper) that does not directly identify you as you interact with our ABI Websites (“Non-Personal Data”). The types of Non-Personal Data we collect includes, but is not limited to:
- Site usage (e.g., browsing history, search terms, number of clicks, referring/exit pages, date/time stamp, time on Site)
- Products and services viewed, including advertisements for such products and services
- Computer type, operating system and platform type
- Internet service provider
- Your industry and business (e.g., company size and location, job functions and seniority levels)
II. HOW WE USE YOUR DATA
In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below, in order to:
A. Personal Data
- Identify you when you visit our ABI Websites
- Provide service communications such as bill reminders, order confirmations, program registrations and customer service messages
- Provide products, information and services you request or that we think you may be interested in
- Respond to your emails or online requests for products, services, or information
- Deliver and process surveys
- Personalize and improve the usability of the ABI Websites
- Fulfill and/or deliver ABI products and services
- Tailor content, advertising and marketing to you
- Publish membership directories, membership lists and registration lists on the ABI Websites to allow members 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. Non-Personal Data
We use Non-Personal Data to improve the usability of our ABI Websites and for other business reasons. We or other third-party companies also use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). We do not provide Personal Data to third parties with whom we share your Non-Personal Data. Please note that, when you select an advertising link or other link that takes you to sites not operated by the ABI, you may be subject to the privacy policies of these third-party sites.
III. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
▪ Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
▪ Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
▪ Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
▪ Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
▪ Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
▪ Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the ABI Websites, which will enable them to collect data about how you interact with the ABI Websites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
▪ Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
▪ Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the ABI Websites. These companies may use information about your visits to the ABI Website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
▪ Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
▪ Other Users. When you share personal information or otherwise interact with public areas of the ABI Websites, such personal information may be viewed by all users and may be publicly distributed outside the ABI Websites in perpetuity. If you interact with other users of the ABI Websites and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within the ABI Websites, and view your profile.
IV. HOW YOU CAN MANAGE THE PROCESSING OF YOUR DATA
You can manage your profile and email preferences, including “opting out” of email by updating your Membership Profile online at abi.org or contacting us using the information in the “Contact Information” section below. If you prefer to receive hard copy mailings only from the ABI, you can contact us 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 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.
V. CALIFORNIA PRIVACY RIGHTS
VI. CANADA ANTI-SPAM LAW
The ABI complies with the Canada Anti-Spam Law. Non-ABI members or associates who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages.
We do not knowingly collect Personal Data from or market to minors under the age of 18. By using the ABI Websites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the ABI Websites. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [email protected]
IX. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
If you choose to register or log in to our services using a social media account, we may have access to certain information about you. ABI Websites offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.
X. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
We may transfer, store, and process your information in countries other than your own. Our servers are located in Alexandria, Virginia, U.S.A. If you are accessing ABI Websites from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in and other countries.
XI. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
XII. HOW WE PROTECT PERSONAL DATA
XIII. USER ID AND PASSWORD
Certain areas of the ABI Websites require the use of a user ID, email address, or password as an additional security measure that helps protect your Personal Data. To help you protect your privacy, these ABI Websites have tools to help you log in and log out.
XIV. HOW YOU CAN ACCESS, CHANGE AND DELETE YOUR PERSONAL DATA
XV. TRANSMISSION OF DATA TO OTHER COUNTRIES
Your Personal Data 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 data. By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.
XVI. RIGHT TO COMPLAIN TO SUPERVISORY AUTHORITY
You, as the data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data does not comply with legal requirements.
XVII. BREACH NOTIFICATION
In the event we determine the occurrence of a data security incident, we will notify you by email, US mail, telephone, or other means as permitted by law.
XVIII. CONTACT INFORMATION
If you have questions, comments, or complaints concerning our privacy practices or if you wish to change, access, or remove your Personal Data, please contact us as indicated below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy related information.