The following information summarizes our personal identifying information gathering and dissemination practices for the SWFRTP's Web site located at the URL, www.SWFRTP.org, and any other site provided by SWFRTP (collectively, the "Site"). Personal identifying information includes information that can be linked to a specific individual, such as a name, address, phone number, picture, or e-mail address.
PLEASE NOTE: THE TYPE OF DATA COLLECTED BY SWFRTP WILL VARY WITH YOUR USE OF THE SITE.
To improve the quality of the products and services SWFRTP offers to you and to operate the Site, SWFRTP collects various personal identifying information (as described below) from different parts of its Site. SWFRTP gathers most information during the registration process for membership and subscription to our newsletters. But, SWFRTP 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 SWFRTP, when you provide nominations for Annual Awards, and when you post information on the Site.
Below, we provide examples of the types of personal identifying information SWFRTP collects through the Site.
Contact Information: SWFRTP requests or requires contact and other personal identifying information, such as your name, address, phone number, facsimile number, and e-mail address.
Demographic Information: SWFRTP collects demographic and profile data (for example, job title, organization, group or area of interest, and technical computer or Internet connection information) at our Site for management and monitoring purposes and to improve the quality of SWFRTP's services. In addition, SWFRTP collects demographic and profile data in connection with surveys it conducts for its own internal administration purposes or for release to third parties. Also, award nominee information including narratives/descriptions, pictures, social media information, and information on the individual submitting nominations is collected.
Transactional Information: SWFRTP maintains a database of aggregated information about the transactions on the Site. 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 four different levels of service: (1) publicly available information areas; (2) members only section (the "Members Only Section"); (3) event and newsletter registration (members and non-members); (4) annual awards nominations. Consequently, you are able to browse the Site without providing any personal identifying information for the publicly available information areas (1). In particular, you do not need to register with SWFRTP or submit any personal identifying information to view information in those sections of the Site that are publicly accessible, such as the About SWFRTP, Newsroom, and Blog 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.
Sections 2, 3, and 4 require that you register with SWFRTP. Accordingly, if you wish to become a member or sponsor, register for events sponsored by SWFRTP, submit nominations for annual awards, receive communications from the SWFRTP and/or participate and receive the results of surveys or other SWFRTP publications, you will need to agree to provide your personal identifying information to be used as discussed below. Please note, however, that the SWFRTP 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 SWFRTP, you share that information only with SWFRTP, unless (i) you are using SWFRTP's services as a part of a third party Web site (in which case information sharing between such third party and SWFRTP will take place in order for the third party to offer SWFRTP's services); (ii) you are completing a transaction involving third party services, such as paying membership fees, 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 SWFRTP uses your personal identifying information.
Contact Information: SWFRTP may use your contact information to provide services, to share your information with others as a part of the Members Only on-line directory, to advertise events (services) to you, to create a personalized experience for you, to provide you with news and information, to contact you regarding a survey, to complete registration and membership renewal communications, to register you for events (members and non-members), to process and publicize award nominations 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 SWFRTP 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: SWFRTP 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, research and industry initiatives.
Technical Information: We use technical information, such as your IP address or browser type, to analyze Site usage trends, track user movements on the Site, and to otherwise manage and monitor our Site.
Business Partners: SWFRTP has partnered with reputable third parties, such as Amazon (among others), to offer you 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, SWFRTP wishes to remind you that such third parties may have different privacy policies and practices than SWFRTP. 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: SWFRTP relies on third party service providers to store and process data on its behalf. We also use other on-line survey tools to conduct surveys both for internal and commercial uses. Information we collect is stored on computer servers operated by Wild Apricot who hosts our site. Wild Apricot is a company located in Toronto, Canada. Their servers are hosted by Amazon Web Services and are distributed over one AWS Region with at least three Availability Zones (data centers).
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.
This section applies to those that visit our Site from the European Economic Area (EEA) or Switzerland.
Lawful Basis for Processing
On most occasions, SWFRTP may process personal data with the individual’s consent (e.g., when a Site visitor agrees that SWFRTP may place cookies, or process information that Site visitor inputs into the Site).
On other occasions, SWFRTP may process personal data when we need to do this to fulfil a contract (for example, for billing purposes) or where SWFRTP is required to do this by law.
If necessary, SWFRTP may also process a Site visitor’s data when it is in SWFRTP’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 section below for contact information.
Transfers of Personal Data
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following action, should a data breach occur:
We will notify the users via email within 2 business days
We will notify the users via in-site notification within 2 business days
We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out penalties for violations.
We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions.
To be in accordance with CANSPAM we agree to the following:
• NOT use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe as indicated below.
If at any time you would like to unsubscribe from receiving future emails, you can email us by including the phrase “stop receiving emails from the SWFRTP” in a reply to the email or by sending an email to email@example.com indicating that you no longer wish to receive correspondence from us and we will promptly remove you from all correspondence.
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 section below. Please be aware that SWFRTP 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. SWFRTP 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 SWFRTP 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 longer if necessary, to meet operational needs of the organization. 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.
SWFRTP utilizes software from Wild Apricot to host the Site to help protect personal identifying information so that it remains private and secure and is not subject to misuse or manipulation. Please see the Wild Apricot privacy statement regarding the control mechanisms that they have implemented. As a user however, you should be aware 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. SWFRTP urges you to take every precaution to protect your personal identifying information when on-line.
The collection, use, and distribution of your personal identifying information is necessary for SWFRTP 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 SWFRTP, who seek to utilize its services or participate in certain events will need to agree to SWFRTP's use and collection of personal identifying information.
But, a number of SWFRTP's other programs are completely voluntary and you can decide on your own if you wish to participate or opt-out. For example, if SWFRTP conducts a survey, you do not have to participate unless you agree to do so and provide your e-mail address in order for SWFRTP to communicate with you.
SWFRTP also provides you with the opportunity to opt-out of certain SWFRTP business practices where your personal identifying information may be used. Specifically, users may opt-out of including the personal identifying information they provide to SWFRTP in connection with the following activities: (i) inclusion on the SWFRTP member directory, (ii) inclusion in member mailings, (iii) e-mail communications sent by SWFRTP, (iv) facsimile communications sent by SWFRTP, and (v) sharing arrangements with SWFRTP's business partners (when not done for the purpose of concluding e-commerce transactions that you execute with SWFRTP for its products and services).
Thus, to a large extent, you can control the information you provide or share with SWFRTP and/or its business partners. Moreover, even when SWFRTP contacts you, from time to time, regarding its products/services, this Site, or otherwise, if SWFRTP sends you such a communication, SWFRTP specifically provides you with the opportunity to opt-out of receiving similar future correspondence by sending an e-mail to info@SWFRTP.org.
At any time, you may contact SWFRTP to correct, modify, or delete the information you provide to SWFRTP 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 info@SWFRTP.org with any requests or changes. Moreover, when you cease to use SWFRTP's services and no longer wish to be included in SWFRTP database, you may contact SWFRTP at info@SWFRTP.org to request to have your information removed from our database. In the event that SWFRTP receives such a request or change, SWFRTP 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 SWFRTP's ability to provide it inoperable.
IF YOU DO NOT AGREE TO THIS POLICY, YOU SHOULD NOT USE THIS INTERNET WEBSITE (OUR “SITE”). WE MAY MODIFY THE POLICY FROM TIME TO TIME AND POST THOSE MODIFICATIONS HERE. YOUR CONTINUED USE OF THE SITE AFTER ANY SUCH MODIFICATION CONSTITUTES YOUR ACCEPTANCE OF THE MODIFIED AGREEMENT.