Privacy For All Americans

Effective: November 13, 2018

This Privacy Policy (“Policy”) describes what information the Internet Association, including any branch offices or affiliates (“IA,” “we,” “our,” or “us”), may obtain about you and the ways in which we use or disclose that information. This Policy applies to our websites, https://internetassociation.org and https://policytable.com, and any other activities or services through which IA may collect personal information. By using the websites, you tell us that you agree to the practices described in this Privacy Policy as it may be updated from time to time.

If you are an individual who is covered by the EU’s General Data Protection Regulation, you may have additional rights and choices. Please review our GDPR section.

Information We Collect

Information You Provide

The IA website is primarily designed to share information with the public about IA’s positions on issues and our activities. We also provide opportunities for visitors to our websites to interact with us. When you interact with us, we may ask you to provide information that we believe is helpful to allow us to respond to your interests, such as when you subscribe to a newsletter.

You may also provide information if you contact us via our websites or using email. In those instances, you will provide us with your email address, email header information, and any information you choose to include in your message to us. From time to time, we post job opportunities at IA, and applicants may choose to provide their resumes and cover letters to IA. Resumes and cover letters are likely to contain full names, addresses, phone numbers, and information on education and work history that the applicant chooses to provide. IA may also collect personal information offline that will be stored electronically and potentially combined with data collected online.

Information That Is Collected Automatically

When you access our websites, IA and our service providers may automatically collect certain technical information from your computer or mobile device. Some of this information is collected as part of the normal operation of the Internet. Other information may be collected as part of our and our service providers efforts to offer services and understand and improve our operations.

The information that may be collected includes things like your Internet Protocol address (“IP address”), your browser type, your operating system, your device and other unique identifiers, the pages you view on the websites, the pages you view immediately before and after you access the websites, and any search terms you enter on the websites. Various technologies can help us determine location, including your IP address, GPS and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and mobile towers.

The technologies we and our service providers use to collect this information are:

• Server logs. When you use our websites, we automatically receive and record certain information from your computer (or other device) and your browser which are stored in logs. Typically, logs record your activity on our websites, including the time and date of your visit, your IP address, and the pages you visit.
• Cookies. We and our service providers use cookies to allow us to recognize whether you have visited the websites before and potentially to store user preferences and other information. Cookies are small files that are stored on your device by your web browser. Both temporary and permanent cookies may be used. Temporary cookies will be removed from your computer each time you close your browser.

  If you are concerned about having cookies on your device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies. However, if you choose to block or delete cookies there is a risk that certain aspects of the websites may not function as expected.

• Web beacons, tags, pixels, scripts, and similar technologies. Our websites or email messages may use applications known as a “web beacon” (also known as a “tags” or “pixels”), scripts, and similar technologies. Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or, in an email message, to transfer data. For example, a beacon can let an email sender know whether an email has been opened.
• Local Shared Objects. We may use Local Storage Objects (LSOs), such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our site may also use LSOs such as HTML5 to collect and store information on our behalf. Various browsers may offer their own management tools for removing HTML5 LSOs.
• Mobile advertising IDs. We and our service providers may use mobile advertising identifiers (such as Apple’s IDFA or Google’s Advertising ID) to collect information for analytics purposes, as described in the section below titled “Third-Party Analytics.”

Information From Third Parties

We may obtain contact information, such as email addresses, from third parties who are able to identify individual professionals at organizations that IA may need to contact in connection with the operation of our organization or that may be interested in obtaining information regarding IA’s activities.

How We May Use Your Information

We and our service providers use the information we collect from you for a variety of purposes which fall into four basic categories. Each of the categories are explained below. If we would like to use your information in a way that is not consistent with the descriptions of these categories, we will contact you to ask your consent to use your information for another purpose.

• To provide you with the service or information you requested or to respond to your correspondence. When you contact IA with a question, event registration, subscription sign-up, job application or other request or information, we will use the personal information you provide to assist us in determining how to respond appropriately (including if no response is necessary).
• To share information about IA news, events, and programs. If you have provided your information to IA, our Members, or certain trusted-third parties and we believe you have an interest in hearing more about IA’s activities, such as upcoming events, news releases, and publications, we may contact you to provide such information. We may also use social media, advertising, or other targeting techniques to promote IA content and programs. If you prefer that we not contact you with these types of messages in the future, you may tell us to stop sending them to you by emailing info@internetassociation.org or using an unsubscribe feature when available. However, we may still contact you to provide administrative notices including any required legal notices.
• To improve our operations, including our websites and programming. We and our service providers may use your information to improve how we run our organization and provide services to our Members and the public. This may include conducting analysis to help us improve the content and functionality of our websites, newsletters, or communications; to better understand our audience and how individuals interact with our content, events, and other offerings; or to improve the systems that provide or support our services.
• To secure our websites, prevent or respond to security threats or legal issues, and to protect the rights of IA and its Members. We may use your information as necessary to protect IA, our Members, and other individuals from: potential threats to the security, integrity, or availability of our systems; potential legal risks such as alleged intellectual property infringement; attempted fraud, manipulation, or other misuse of our systems or content; and any threat to the safety or security of any person or place. This includes sending any required notices, as well as sending notices that are not legally required, but are intended for your protection or the protection of others.

How We May Disclose Your Information

We may disclose the information we collect from you as described below:

• to service providers wehave hired to help us operate our organization;
• to business partners whomay deliver marketing communications, promotional materials, or advertisementsthat may be of interest to you;
• as required by law, such asto comply with a subpoena or other legal process, or to comply with governmentreporting obligations;
• when we believe in goodfaith that disclosure is necessary (a) to protect our rights, the integrity ofthe websites, or your safety or the safety of others, or (b) to detect,prevent, or respond to fraud, intellectual property infringement, violations oflaw, or other misuse of the websites;
• to any IA branch offices, affiliates,and subsidiaries;
• to third parties with embeddedcontent or plugins on our websites (such as a embedded video content from athird-party service).  Even if you do notclick on these embedded content or plugins, they may collect information aboutyou, such as your IP address and the pages that you view.  They also may set and/or access a cookie or usesimilar tracking technologies.  Embeddedcontent and plugins are governed by the privacy policy of the company hostingthe embedded content or providing the plugin;
• service providers,advisors, and other third parties to the extent reasonably necessary to proceedwith the negotiation or completion of a merger, acquisition, or sale of all ora portion of our assets.

In addition, we may share aggregate reports on user demographics and traffic patterns, as well as de-identified information, with third parties.

Third-party Analytics

We may partner with certain third parties to collect, analyze, and use information to engage in analytics, auditing, research, and reporting. These third parties may set and access cookies on your device and use web beacons, tags, or similar technologies. They also may collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by IA. Like many other online services, our websites do not respond to “do not track” browser signals.

One of the third-parties we use is Google Analytics. You may want to review information Google has made available about their collection and use of personal information. Google Analytics provides users with certain choices and tools to manage their personal information. Please see: https://tools.google.com/dlpage/gaoptout/

Third-party Content And Activity

The websites may contain links to websites or mobile apps of third parties, including social media sharing features that link to third-party services. If you follow a link to any of these websites or apps, please note that these websites and apps, and any services that may be accessible through them, have their own privacy policies. We are not responsible for the privacy practices of other websites or apps or the information you share through such other websites or apps. We encourage our users to be aware when they leave the websites and to read the privacy policies applicable to such third-party websites and apps. This Privacy Policy applies solely to information collected in the manner described in this Policy.

Your Choices

IA recognizes that you have an important interest in exercising control over how your information is used. You may contact us with questions or to request the following:

• an update to your contact information;
• to obtain a copy of your information;
• to no longer receive marketing communications from us; or
• for us to not share your information with third parties formarketing purposes.

You may also exercise certain choices through your browser:

• Cookies: If you do not want the websites to collect information through cookies, you can set your web browser to reject cookies from the websites. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. If you reject or block cookies from the websites, however, the websites may not function as intended.
• Google Analytics Opt-Out: Please see https://tools.google.com/dlpage/gaoptout/
• Do Not Track Signals: We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy. Visit the following website, www.allaboutdnt.org, for more information on this developing area.

If you are an individual who is covered by the EU’s General Data Protection Regulation, you may have additional rights and choices. Please our GDPR section.

Where We Process Information

Information collected through the websites will be processed in and subject to the laws of the United States. Information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries. These countries may not provide as much protection for your personal information as the laws of your home country. By using the websites, you consent to such transfer to, and processing in, the United States and other countries.

How Information Is Secured And Retained

IA takes reasonable and appropriate measures to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users should also be mindful that there may be risks associated with transmitting information to the websites over networks, including the Internet and wireless networks, that IA does not control.

IA will retain information we collect for a period of time that is appropriate to the purposes for which it is processed. To determine an appropriate retention period, we will consider criteria including: the likelihood that the data is still accurate and relevant to the purposes for which it is processed; whether the data could be kept in a form that does not identify individuals; the sensitivity and security risks of continued storage; and the organization’s interest in archiving public policy debates for historical purposes.

Children’s Information

The websites are not directed to, nor do we knowingly collect information from, children. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us.

Changes To This Privacy Policy

We may change this Policy from time to time. When we update this Policy, we will post the changes on this page and update the effective date. If you continue to use the websites after those changes are in effect, you agree to the new Policy. If the changes are significant, we may provide a more prominent notice or ask for your consent, as required by law.

Contact Us

The Internet Association is the data controller responsible for this Privacy Policy and the practices it describes. If you have any questions about this Privacy Policy, please contact us at info@internetassociation.org or by mail at:

Internet Association
ATTN: Privacy
660 North Capitol Street, NW, Suite 200
Washington, DC 20001

Or in the United Kingdom:
Internet Association
ATTN: Privacy
50 Broadway
London
Greater London
SW1H 0RG
United Kingdom

Additional Provisions For Individuals Covered By The EU’s GDPR

If you are located in the European Union, these additional provisions may pertain to your use of IA’s websites or other services. Please review them carefully to learn about rights you may have based on your jurisdiction.

Legal Bases For Processing Personal Information

In most instances, the information we collect and process is necessary to fulfill a request you have made, such as: to view our webpage, answer a question sent by email, apply for a job, attend an event, or subscribe to our newsletter. IA and our service providers have legitimate interests in processing your information to fulfill these requests and to operate and improve the websites and any of our other services. Our interests in processing your information are not absolute and we will not rely on legitimate interests to process your information if we determine that our interests are overridden by your rights. You may object to our processing based on our legitimate interests as described further below in Your Rights And Choices.

Depending on the context, we may also rely on these additional legal bases:

• Contract. We may process your information if you enter into an agreement with us and the processing is necessary to fulfill the contract.
• Consent. When we rely on your consent to process your information, you may revoke your consent if you would like us to stop. Please see Your rights and choices.
• Legal obligation. We may be required to use your personal information to comply with the law. For example, if we receive a court order we may be required to disclose information.

Data Transfers

IA will take appropriate steps to determine that transfers of your data are appropriate in light of our contractual arrangements with third party recipients and any applicable legal requirements.

Your Rights And Choices

You have several rights and choices you may exercise under the terms of the General Data Protection Regulation. We will respond to your requests to exercise these rights consistent with obligations we may have under the GDPR.

• Access. You have a right to obtain access to your information.
• Rectification or Deletion. You have a right to obtain our cooperation to rectify or delete your information in certain circumstances.
• Restriction. You have a right to restrict our processing of your information under certain circumstances.
• Objection. You have a right to object to continued processing of your information, including for direct marketing purposes. If we are processing your information for reasons other than direct marketing, our legitimate interests may allow us to continue processing your information.
• Revocation of consent. You may withdraw your consent when we rely on it to process your information.
• Lodging complaints. You have a right to make a complaint regarding our practices to the supervisory authority of your choosing, including the one where you reside or the one where we reside (The U.K. Information Commissioner’s Office).

If you would like to contact us to exercise one of these rights, to ask a question, or to express a complaint regarding our privacy practices, please email: info@internetassociation.org.