Effective as of November 2017
Transparency/Notice-What Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with USAFCG and the requirements of applicable law. Below are some of the ways we collect information and how we use it.
INFORMATION USAFCG COLLECTS
In general, USAFCG collects information from you based upon our business relationship, your use of our websites and services, and includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, Internet Protocol address, and potentially billing and payment information related to payments for Services or programs.
HOW USAFCG COLLECTS PERSONAL INFORMATION
Some of the ways that USAFCG may collect your Personal Information include:
- USAFCG may collect Personal Information from you through various channels, including the Services, in surveys, during business or marketing events, and when delivering programs and Services to you.
- When you use the Services, USAFCG may provide you with opportunities to sign up to receive specific information and may ask for your contact information (e.g. name, company name, company address, phone number or email address), so that we can send you specific information about our products, Services, with your consent.
- As you navigate the websites and use the Services, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, advertisements clicked, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, your browser settings, your mobile device type, the date and time you access our Services and other device identifiers. This type of information is used for the purposes of gathering data to provide improved administration of our Services, and to improve the quality of your experience when interacting with our Services.
INFORMATION FROM THIRD-PARTY SOURCES
USAFCG may collect information about you from Third-Party sources to supplement information provided by you, including Internet Protocol addresses, cookies, navigational data and advertisements clicked. This supplemental information allows us to verify information that you have provided to USAFCG and to enhance our ability to provide you with information about our business, products and Services. USAFCG’s agreements with these Third Party-sources typically limit how we may use this supplemental information.
From time to time, USAFCG may perform research (online and offline) via surveys. We may engage Third Party-service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
HOW USAFCG USES YOUR PERSONAL INFORMATION
Depending on how you interact with USAFCG, we and our Third Party-service providers may also use Personal Information in a variety of ways, including:
- Providing Information and Services You Requested. USAFCG may use the Personal Information about you to fulfill requests for programs, Services, or information that you may request, including information about potential or future Services, including to: (a) generally manage your information and accounts; (b) respond to questions, comments and requests; (c) provide access to certain areas and features of the Services; and (d) allow you to register for events or participate in webinars.
- Marketing Products and Services. USAFCG may use the Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or information about future services on USAFCG’s websites. USAFCG may provide you with these materials by phone, postal mail, fax or email, as permitted by applicable law. Such uses include: (a) to tailor content, advertisements, and offers; (b) to notify you about offers, products, and services that may be of interest to you; (c) to provide Services to you; (d) for other purposes disclosed at the time that you provide Personal Information; or (e) otherwise with your consent. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.
- Research and Development. USAFCG may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products, processes and services.
- Anonymous and Aggregated Data. USAFCG may use and share your anonymized or aggregated information for internal purpose or with Third Parties for research, analytics and any other legally permissible purposes.
- Other Uses. USAFCG may use your Personal Information for other purposes disclosed to you at the time you provide Personal Information or with your consent.
Generally, online social media resources are interactive tools that enable individuals to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.
USAFCG may collect Personal Information to enable individuals to use online social media resources offered either by USAFCG or a Third Party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
DIRECT MAIL AND EMAIL MARKETING
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters or mailings from us with information on USAFCG or our business partners’ products and Services or upcoming special offers/events we believe may be of interest.
ALL INTERNET USERS – COOKIES, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
Like many other websites, USAFCG or its business partners may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time an Individual initiates a session on USAFCG’s websites. A cookie is set in order to identify visitors; tailor our websites to you; measure and research the effectiveness of our websites’ features, offerings and advertisements; and authenticate users for registered Services. Cookies can only access Personal Information that you have provided on our websites and cannot be accessed by other sites. Individuals also have the ability to delete cookie files from their own hard drive at any time by clicking on the Privacy or History tab typically found on the Settings or Options menu in your internet browser. However, please also be advised that cookies may be necessary to provide access to much of the content and many of the features of USAFCG’s websites.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our websites, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ . You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout .
Through our websites, USAFCG may in the future allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-Personal Information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-USAFCG related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”
USAFCG may provide websites, applications and online resources that are specifically designed to be compatible and used on mobile devices. USAFCG will collect certain information that your mobile device sends when you use such websites, applications or online resources, like a device identifier, location, user settings and the operating system of your device.
ANONYMOUS AND AGGREGATED INFORMATION
USAFCG may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the websites or other online Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and USAFCG may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within USAFCG and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Choice/Modalities to Opt Out
Where you have consented to USAFCG’s Processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Note that, due to the nature of the Services, you may have to provide the email or other identifying value that is associated with your Personal Information in order for USAFCG to segregate out the use and retention of such Personal Information.
Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the individual, USAFCG will endeavor to obtain each individual’s explicit consent (opt-in). Where consent of the individual for the Processing of Personal Information is otherwise required by law or contract, USAFCG will comply with the law or contract.
“DO NOT TRACK”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. At this time, there is no general agreement on how companies like USAFCG should interpret DNT signals. Therefore, USAFCG does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. For information about “do-not-track”, visit http://www.allaboutdnt.org.
INFORMATION WE SHARE
USAFCG may share Personal Information with our service providers that we have retained to perform Services on our behalf including (i) provision of IT and related Services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.
USAFCG has executed appropriate contracts with our service providers that prohibit service providers from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
From time to time, USAFCG may partner with other companies to jointly offer products, services or programs (such as webinars, events or downloadable content). If you purchase, specifically express interest in or register for a jointly-offered product, service or program from or through USAFCG, we may share your Personal Information collected in connection with your purchase or expression of interest with our business partners. USAFCG does not control our business partners’ use of shared Personal Information and their use of such information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.
INFORMATION DISCLOSED FOR OUR PROTECTION AND THE PROTECTION OF OTHERS
We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce USAFCG policies or contracts; (v) to collect amounts owed to USAFCG; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing Personal Information may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
INFORMATION DISCLOSED IN CONNECTION WITH BUSINESS TRANSACTIONS
USAFCG primarily stores Personal Information sent or collected via or by USAFCG in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. To facilitate USAFCG’s global operations, we may transfer, store and access such information from around the world. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to USAFCG, you consent to the storage of your Personal Information in these locations.
DATA PROTECTION ADDENDUM
While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering a Data Protection Addendum (DPA) to our agreement.
Rights of Access, Rectification, Erasure and Restriction
YOUR PERSONAL INFORMATION
As a data processor for our Customers, USAFCG Processes data that may include Personal Information of Users (“Customer Data”). USAFCG will not review, share, distribute or reference any such Customer Data except as provided in the agreements between us and our Customers, or as may be required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Customer Data and you wish to exercise any rights you may have to access, correct, amend or delete such data, please inquire with the relevant Customer directly. Because USAFCG personnel have limited ability to access Customer Data, if you wish to make your request directly to USAFCG, please provide the name of the relevant USAFCG customer. We will refer your request to that Customer, and will support them as needed in responding to your request within a reasonable timeframe.
The security of all Personal Information provided to USAFCG is important to us, and USAFCG takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while USAFCG strives to protect your Personal Information, we cannot ensure or warrant the security of information you transmit to USAFCG. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify USAFCG at [email protected]
Redress/Compliance and Accountability
USAFCG will address your concerns and attempt to resolve any privacy issues in a timely manner.
Other Rights and Important Information
LINKS TO THIRD-PARTY DIGITAL PROPERTIES
CHANGES TO THE PRIVACY STATEMENT
“Personal Information” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any natural or legal person, public authority, agency or body other than the Individual, USAFCG or USAFCG’s agents.
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