Website Privacy Statement
Updated as of May 3, 2023
INFORMATION WE COLLECT ABOUT YOU
We may collect the following categories of information about you which are described in more detail below: (A) information you provide to us, (B) sensitive Information, (C) information we may automatically collect, and (E) information we may receive from third parties. All of the information listed in (A)-(C), (E) above, are detailed below, and hereinafter referred to as “Information.”
A. Information You Provide to Us
When using our Services, you may provide us with Information, including, without limitation:
- Individual identifiers such as name, gender, age, telephone number, mailing address;
- Employment information such as company and job title;
- Communications with us, preferences, and other Information you provide to us such as any messages (including via online chat feature), opinions and feedback that you provide to us, your user preferences (such as in receiving updates or marketing information), and other Information that you share with us when you contact us directly (such as for customer support services); and
- Additional Information as otherwise described to you at the point of collection or pursuant to your consent.
B. Sensitive Information
With your consent, we may process the following categories of sensitive personal Information when you use our Services:
- Geolocation data.
C. Information We May Automatically Collect About You
Our Services may automatically collect the following categories of usage and technical Information about you. This Information is used by NAMSA for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Services. This Information may include:
NAMSA also may automatically collect information about your computer hardware and software. This information can include:
- Your IP address,
- Browser type,
- Application type,
- Domain names,
- Access times,
- Your movement and activity within the website, which is aggregated with other Information, and
- Referring Website addresses.
D. Cookies & Technologies Used to Collect Information About You
We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this Information by using certain technologies, such as cookies, web beacons, pixels, software developer kits, third party libraries, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.
- Web Beacons. Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Services use retargeting pixels from Google, Facebook, and other ad networks. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.
- Mobile Application Technologies. If you access our website and Services through a mobile device, we may automatically collect Information about your device, your phone number, and your physical location.
Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under certain laws, you can opt-out of these online tracking technologies by submitting a request via [INSERT LINK] or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC). Please note that some features of our website may not be available to you as a result of these choices.
E. Information We May Receive from Third Parties
We may collect additional Information about you from third-party websites, social media platforms and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.
HOW WE USE YOUR INFORMATION
A. Use and Purpose of Processing Your Information
We use and process your Information for things that may include, but are not limited to, the following:
|Categories of Personal Information||Objectives of the Processing|
|Identification information, application usage data (e.g., features/pages accessed by a member), location data (GPS).||To operate and improve the Services.|
|Identification information, application usage data (e.g., features/pages accessed by a member), location data (GPS).||To understand and analyze information related to the number and type of visitors that browse and use the Services.|
|Name, phone number, mailing address, email address, company, job title.||To provide you with email alerts, information, products, Services, and other correspondence that you request from NAMSA, or that may be of interest to you, either from NAMSA or its third parties.|
|Name, phone number, mailing address, email address.||To respond to your comments, inquiries and questions and provide customer Services.|
|Name, phone number, mailing address, email address.||To permit you to participate in social sharing, including live social media feeds.|
|Name, phone number, mailing address, email address.||To contact you via surveys to conduct research about your opinion of current Services or of potential new Services that may be offered.|
|Name, phone number, mailing address, email address.||To send administrative information to you, for example, information regarding the Services and changes to NAMSA’s terms, conditions, and policies. Because this information may be important to your use of the Services, you may not opt-out of receiving these communications.|
|Name, mailing address, email address, phone number, demographic information.||To allow you to participate in interactive features on our Services or to participate in webinars and other information resources offered through the Services and to administer these activities, as applicable.|
|Name, mailing address, email address, phone number, demographic information.||To link or combine with other personal information we get from third parties, to help understand your needs and provide you with better information on the Services.|
|Name, mailing address, email address, phone number, demographic information.||To fulfill any other purpose for which you provide it or for which you have given us consent to use it.|
You can opt-out of certain use(s) of your Information, as described below.
B. Sharing or Disclosing Your Information
- Third-Party Service Providers. We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.
- Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates, and any of their officers, directors, employees, attorneys, agents, contractors, and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
- Business Transfers. Your Information may be transferred, sold, or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize.
- Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates.
- De-Identified or Aggregated Data. We may share your Information on an aggregated basis for any purpose in which your specific personal Information is blinded, masked, or otherwise not identifiable.
LINKS TO OTHER WEBSITES
Our Services may contain links to other websites or services that are not owned or controlled by us, including links to Social Media Platforms such as Facebook, Instagram, or YouTube, or may redirect you off our website away from our Services.
We use commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Services and safeguard your information. However, no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.
If you believe that your Information has been accessed or acquired by an unauthorized person, you should promptly contact us so that necessary measures can quickly be taken.
You can always opt not to disclose information to NAMSA. However, some information may be needed to register with NAMSA or for NAMSA to provide its Services.
Opting Out of Direct Marketing by Third Parties
To exercise choices regarding the marketing information you receive, you may also review the following links:
- You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at http://www.aboutads.info/appchoices
- You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info
- You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.
At any time, you can withdraw your consent and opt-out of receiving promotional or marketing communications from NAMSA by using the unsubscribe link in the emails communications or by sending an email to firstname.lastname@example.org.
If you have any account for our Services, NAMSA will still send you non-promotional communications, like service-related emails.
NOTICE TO CERTAIN RESIDENTS OF DATA SUBJECT RIGHTS
ANOTICE TO CALIFORNIA RESIDENTS
- Your Rights under CCPA
- Right to Know and Access Specific Information. You have the right to request that we disclose certain information to you about our collection and use of your Information over the past twelve (12) months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you, to the extent permitted by law:
o The categories of Information we collected about you, and whether we sell or share your information to third parties.
o The specific pieces of Information we hold about you.
o The categories of personal information sold within the last 12 (twelve) months.
o The categories of sources from which Information about you is collected.
o Our business or commercial purpose for collecting, selling, or sharing your Information.
o The categories of third parties with whom your Information is sold, shared, or disclosed for a business purpose.
You have the right to request that the Information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability”).
- Deletion Request Rights. You have the right to request that we delete the Information that we collected from you, subject to certain exceptions. To the extent that we can delete your Information, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Information, unless an exception applies.
- Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your verifiable consumer request, we will use commercially reasonable efforts to correct your personal Information.
- Sale and Sharing of Personal Information and the Right to Opt-Out. You have the right to opt out of the processing of your Information for the following purposes:
o Sale of your Information.
o Sharing of your Information for cross-context behavioral advertising.
The use of online tracking technologies may be considered a “sale” or “sharing” under California law. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under California law, you may opt-out of these online tracking technologies by submitting a request via [INSERT LINK] or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC).
- Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the ways we use and disclose your sensitive personal Information (as defined by CCPA) to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or and as authorized by law.
- Right to Non-Discrimination. You have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity. As a result of your data subject request activity, we may not and will not deny goods or Services to you, charge different rates for goods or Services, provide a different level quality of goods or Services, or suggest that we would treat you differently because of your data subject request activity.
- Right to Disclosure of Direct Marketers. You have a right to the categories and names/addresses of third parties that have received personal Information for their direct marketing purposes upon simple request, and free of charge.
To exercise the rights described above, see the Exercising Your Rights section below.
- Authorized Agent
You may use an authorized agent to submit verifiable consumer requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to California Probate Code sections 4000 to 4665. We may deny a request from an authorized agent that does not submit proper verification proof.
- Notice of Financial Incentive
As an incentive for providing us with your Information, you may receive a financial benefit in the form of an email coupon, discount, rebate, free sample, promotions, or other similar reward that will be sent to you. This discount may constitute a financial incentive under the California Consumer Privacy Act (“Financial Incentive”). The categories of personal Information required for us to provide the Financial Incentives include personal identifiers such as full name and contact information including email address as well as personal and demographic information you choose to provide.
To offer these discounts, we may track your personal Information, such as purchase history and other demographic data. You have the right to withdraw from the Financial Incentive at any time by submitting a request to email@example.com. Please note that if you request deletion of part or all your personal Information, that could affect your ability to qualify for the discount.
- Additional Information
To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
California Shine the Light Requests
California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by NAMSA to third parties for the third parties’ direct marketing purposes. To make an opt-out request of such disclosures, please send an email to firstname.lastname@example.org or call us at 1-866-666-9455.
- NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND THE UK
This section applies only to individuals coming to our Services from within the European Union (EU), the European Economic Area (EEA), and the UK, and only if we collect through the Services any Information from you that is considered “Personal Data,” as defined in the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.
- Identity and Contact Details of Controller and EU Representative
Unless otherwise stated, we are the Data Controller for the Information we process.
- Your Data Protection Rights
To the extent the GDPR and Data Protection Act 2018 apply, and we hold your Information in our capacity as a Data Controller as defined under those laws, you may request that we:
- Restrict the way that we process and share your Information;
- Transfer your Information to a third party;
- Provide you with access to your Information;
- Remove your Information if no longer necessary for the purposes collected;
- Update your Information so it is correct and not out of date; and/or
- Object to our processing of your Information.
Call us: 1-419-666-9455 (outside of USA)
The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional Information from you to confirm your identity in responding to such requests.
You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at:
Call us: 1-419-666-9455 (outside of USA)
- Lawful Basis for Processing Your Information
Depending on what Personal Data we collect from you and how we collect it, we may also rely on various grounds for processing your Personal Data, including the following reasons:
- Processing on the basis of legitimate business interests. When we process Personal Data on the basis that the processing is necessary for our legitimate business interests, such interests include:
- To understand how people use our products and services.
- To perform background checks necessary to verify employment eligibility.
- To provide customer support.
- To optimize our service and develop new services.
- For research and analytical purposes.
- For direct marketing purposes. This includes, for example, analysing data to identify trends and tailor marketing messages to user needs.
- Processing on the basis of performance of a contract. Examples of situations in which we process Personal Data as necessary for performance of a contract include e-commerce transactions in which you purchase a service from us.
- Processing on the basis of consent. Examples of processing activities for which we may use consent as its legal basis include: (i) collecting and processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing Personal Data on Company Services through cookies and similar technologies when consent is required by applicable law.
- Processing because we are under a legal obligation to do so. Examples of situations in which we must processes Personal Data to comply with our legal obligations include: (i) providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (ii) retaining business records required to be retained by applicable laws; and (iii) complying with court orders or other legal process.
If the processing of your Information is based on your consent, the GDPR and Data Protection Act 2018 also allow users the right to access, revoke, or modify your consent at any time. Please see the Contact Information section, below, to review or modify your consents.
- Consent to Transfer
Our Services collect Information and process and store Information in databases located in the United States. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Services and submitting any personally identifiable Information you consent to the transfer of such personally identifiable Information to the United States. However, NAMSA is committed to protecting your information in accordance with this Privacy Notice and is self-certified under the EU-US Privacy Shield and the Swiss-US Privacy Shield frameworks. For more information on NAMSA’s compliance with these frameworks, please visit our NAMSA EU – U.S. AND SWISS – U.S. PRIVACY SHIELD Statement.
- Whether we need the Information to provide the Services. We will maintain any data needed to provide you with the Services, such as contact information and payment or transaction information, for as long as needed for us to provide you with the Services, respond to your questions and requests, and/or administer your account (if applicable).
- Whether we need the Information to comply with our legal obligations. We may have legal obligations to maintain your Information where a legal or regulatory body may ask for it in the future, for example in response to a data subject request or complaint. This information may include contact information and location information.
- Whether we need the Information for a legitimate business interest. We may store Information like contact information, cookies, and location information in order to perform analytics, troubleshoot errors, or improve our Services. In any event, we delete the Information when it is no longer needed for our legitimate interest.
Regardless of our reason for retaining your information, we delete all Information in accordance with our routine record keeping policies.
NAMSA retains your Information for as long as necessary to provide you Services, and as necessary to comply with our legal obligations resolve disputes, and enforce our policies. If you wish to request that we no longer use your Information to provide you Services, please contact us at email@example.com. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.
EU-US Privacy Shield and Swiss-US Privacy Shield
NAMSA is self-certified under the EU-US Privacy Shield and the Swiss-US Privacy Shield frameworks. For more information on NAMSA’s compliance with these frameworks, please visit our NAMSA EU – U.S. AND SWISS – U.S. PRIVACY SHIELD Statement. If there is any conflict between the terms in this Privacy Statement and applicable Privacy Shield Principles, the Privacy Shield Principles shall govern.
EXERCISING YOUR DATA SUBJECT RIGHTS
In order to exercise any of the data subject rights described above, or to inquire into more information, please submit a verifiable consumer request to us via the methods described below:
NAMSA World Headquarters
6750 Wales Road
Northwood, OH USA 43619
419.666.9455 (outside of U.S.)
NAMSA’s Privacy Team will review any request and respond within a reasonable time.
Only you or a person authorized to act on your behalf, may make a request related to your Information. You may also make a request on behalf of your minor child. You may only make a consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Information, or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
To help protect your privacy and maintain security, if you request access to or deletion of your Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).
NAMSA cannot respond to your request or provide you with your personal information if NAMSA cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a data rights request does not require you to create an account with us. We will only use personal information provided in a data request to verify the requestor’s identity or authority to make the request.
GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING
Our Services are targeted to individuals located in the United States. As such, the Services collect Information and process and store that Information in databases located in the United States. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Services and submitting any personally identifiable Information you consent to the transfer of such personally identifiable Information to the United States.
The Services are intended only for users over the age of eighteen (18). If we become aware that a user is under thirteen (13) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us at firstname.lastname@example.org if you believe that we have mistakenly or unintentionally collected Information from a child under the age of thirteen (13).
“DO NOT TRACK” SIGNALS
We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of personal Information, or the use of sensitive personal Information.
NAMSA World Headquarters
6750 Wales Road
Northwood, OH USA 43619
419.666.9455 (outside of U.S.)