Effective Date: May 25, 2018
The following information summarizes our personal identifying information gathering and dissemination practices for the ITI's United States Web site located at the URL, www.itic.org, and any other site provided by ITI (collectively, the "Site"). Personal identifying information includes information that can be linked to a specific individual, such as a name, address, phone number, or e-mail address.
What Information Does ITI Collect?
PLEASE NOTE: THE TYPE OF DATA COLLECTED BY ITI WILL VARY WITH YOUR USE OF THE SITE.
To improve the quality of the products and services ITI offers to you and to operate the Site, ITI collects various personal identifying information (as described below) from different parts of its Site. ITI gathers most information during the registration process to use ITI's services and products. But, ITI requests personal identifying information at other times, including, but not limited to, when you report a problem with our Site, when you complete survey forms, when you enter into a transaction through the Site, when you request to receive communications from ITI, and when you post information on the Site.
Below, we provide examples of the types of personal identifying information ITI collects through the Site. Again, please be aware that the type of data collected by ITI will vary with your use of the Site.
Contact Information: ITI requests or requires contact and other personal identifying information, such as your name, address, phone number, facsimile number, and e-mail address.
Demographic Information: ITI collects demographic and profile data (for example, job title, job position, and technical computer or Internet connection information) at our Site for management and monitoring purposes and to improve the quality of ITI's services. In addition, ITI collects demographic and profile data in connection with surveys it conducts for its own internal administration purposes or for release to third parties.
Transactional Information: ITI maintains a database of aggregated information about the transactions on the Site (e.g., offer/request data, product/service categories, and product/service prices).
Technical Information: We also collect Internet Protocol (IP) addresses from all users of our Site and may catalog the type of computer, browser, or operating system used by the user.
The Site offers two different levels of service: (1) a members only section (the "Members Only Section"); and (2) publicly available information areas. Consequently, until you register to access a Members Only area, you are able to browse the Site without providing any personal identifying information. In particular, you do not need to register with ITI or submit any personal identifying information to view information in those sections of the Site that are publicly accessible, such as the About ITI, Public Policy and Newsroom sections. Entry will be permitted without any need to login, although your browser may tell us what type of computer and operating system you are using as well as other kinds of technical information.
Only the Members Only Section requires that you register with ITI. Accordingly, if you wish to become a member, you will need to agree to provide your personal identifying information to be used as discussed below. In addition, if you wish to receive information from ITI, order products and services from ITI, be included in the ITI member directory, and/or participate and receive the results of surveys, then ITI will need to receive your personal identifying information, and in particular, your name and e-mail address for communication purposes. Please note, however, that the ITI member directory lists a registered member's name, e-mail address, and certain demographic information such as title, employer, office phone number, and office address. When you provide personal identifying information to ITI, you share that information only with ITI, unless (i) you are using ITI's services as a part of a third party Web site (in which case information sharing between such third party and ITI will take place in order for the third party to offer ITI's services); (ii) you are completing a transaction involving third party services, such as viewing the ITI scorecard through CapWiz, in which case information sharing will be necessary to enable the transaction to take place; or (iii) it is specifically stated otherwise.
Below, is more detail on how ITI uses your personal identifying information.
How Does ITI Use and Share That Information?
Contact Information: ITI may use your contact information to provide its goods and services, to share your information with others as a part of the Members Only on-line directory, to advertise its goods and services and the goods and services of third parties, to create a personalized experience for you, to provide you with news and information, to contact you regarding a survey, to complete a transaction for goods and services, and to get in touch with you when necessary with respect to transactions conducted through the Site, material changes in our Site's policies, new services ITI may offer, or otherwise. We do not share your contact information with other types of third parties for any other purpose, except to a court or governmental agency if required by law.
Survey Results: ITI may share, lease rent, license, and/or sell survey results and aggregated demographic data collected through the Site with the general public, the news media, and with the U.S. Government and state governments, not only as may be required by law, but also to participate in government programs and initiatives.
Technical Information: We use technical information, such as your IP address or browser type, to help diagnose problems with our servers, analyze Site usage trends, track user movements on the Site, and to otherwise manage and monitor our Site.
Business Partners: ITI has partnered with reputable third parties, such as CapWiz, to offer you a variety of products and services and as noted above, does share certain of your personal identifying information (as indicated above) with such business partners. In accordance with these business arrangements, ITI wishes to remind you that such third parties may have different privacy policies and practices than ITI. We encourage you to review the privacy policies of our business partners to further understand their procedures for collecting, using, and disclosing your information.
Service Providers: ITI relies on third party service providers to store and process data on its behalf.
We may work with third parties that collect data about your use of our Site for non-advertising purposes. We use Google Analytics to improve the performance of our Site and for analytics purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
We do not use automatic decision-making or engage in profiling.
What About External or Third Party Web Sites?
This section applies to those that visit our Site from the European Economic Area (EEA) or Switzerland.
Lawful Basis for Processing
On most occasions, ITI may process personal data with the individual’s consent (e.g., when a Site visitor agrees that ITI may place cookies, or process information that Site visitor inputs into the Site).
On other occasions, ITI may process personal data when we need to do this to fulfil a contract (for example, for billing purposes) or where ITI is required to do this by law.
If necessary, ITI may also process a Site visitor’s data when it is in ITI’s legitimate interests to do this (e.g., for fraud detection or certain direct marketing purposes) and when these interests are not overridden by the individual’s data protection rights.
If you wish to exercise the right to withdraw consent, visit the “Contact Us” section below for contact information.
Transfers of Personal Data
You have a right to the following:
- To request access to the personal data we hold about you;
- To request that we rectify or erase your personal data;
- To request that we restrict or block the processing of your personal data;
- Under certain circumstances, to receive personal data about you that we store and transmit to another without hindrance from us, including requesting that we provide your personal data directly to another, i.e., a right to data portability; and
- Where we previously obtained your consent, to withdraw consent to processing your personal data.
To exercise these rights, see the “Contact Us” section below. Please be aware that ITI may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.
We will process and store your personal data only for the period necessary to achieve the purpose of the storage, or as permitted by law. ITI stores personal data associated with membership as long as the membership is active and then for a reasonable time after membership is terminated for the convenience of its members, and ITI stores personal data used for subscriptions until the subscriber opts out. The criteria used to determine the period of storage of personal data is the respective statutory retention period or [insert other criteria used to determine storage period for data that does not have a statutory retention period]. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of a contract or the initiation of a contract.
What About Security?
ITI places a premium on making sure that personal identifying information remains private and secure and is not subject to misuse or manipulation. Accordingly, this Site has industry standard security measures in place, including storage of personal identifying information in a secure environment, to protect against the loss, misuse, and alteration of the information under ITI's control. Although ITI has endeavored to create a secure and reliable Site, the confidentiality of any communication or material transmitted via the Internet cannot be guaranteed. Accordingly, you should consider carefully if you want to submit sensitive information via the Internet. ITI urges you to take every precaution to protect your personal identifying information when on-line.
What Are My Choices Regarding Data Collection and Use?
The collection, use, and distribution of your personal identifying information is necessary for ITI to provide certain products and services and to operate the Site. For example, all users who register for the Members Only Section and/or seek to receive from ITI its products will need to agree to ITI's use and collection of personal identifying information.
But, a number of ITI's other programs are completely voluntary and you can decide on your own if you wish to participate or opt-out. For example, if ITI conducts a survey, you do not have to participate unless you agree to do so and provide your e-mail address in order for ITI to communicate with you.
ITI also provides you with the opportunity to opt-out of certain ITI business practices where your personal identifying information may be used. Specifically, users my opt-out of including the personal identifying information they provide to ITI in connection with the following activities: (i) inclusion on the ITI member directory, (ii) inclusion in member mailings, (iii) e-mail communications sent by ITI, (iv) facsimile communications sent by ITI, and (v) lease, rental, or sharing arrangements with ITI's business partners (when not done for the purpose of concluding e-commerce transactions that you execute with ITI for its products and services).
Thus, to a large extent, you can control the information you provide or share with ITI and/or its business partners. Moreover, even when ITI contacts you, from time to time, regarding its products/services, this Site, or otherwise, if ITI sends you such a communication, ITI specifically provides you with the opportunity to opt-out of receiving similar future correspondence by sending an e-mail to firstname.lastname@example.org.
What About Correcting, Deleting, or Updating Information?
At any time, you may contact ITI to correct, modify, or delete the information you provide to ITI through this Site, namely, your name, e-email address, phone number, or address. In addition to the ability to make direct changes to the information stored in connection with your user/member profile, you may also e-mail email@example.com with any requests or changes. Moreover, when you cease to use ITI's services and no longer wish to be included in ITI database, you may contact ITI at firstname.lastname@example.org to request to have your information removed from our database. In the event that ITI receives such a request or change, ITI may require you to confirm or verify any change to your record. Please note, however, that the collection and uses of certain personal identifying information is necessary to provide certain products and services through the Site and the deletion of such necessary information, e.g., an e-mail address, may render a particular service or ITI's ability to provide it inoperable.
For visitors from the EEA, to contact our representative, please use the contact information above.