Effective Date: June 1, 2018
If no Entity has been clearly identified, the data controller or data controllers may be identified in the following order or precedence:
We (or our services providers on our behalf) may collect your Personal Information. “Personal Information” means information relating to an identified or identifiable natural person. For example, Personal Information may include:
We also may collect information about your use of the Online Services, such as your browser information, pages clicked, and time spent navigating the site. This information cannot be used to identify you. If we link this information with any Personal Information, we will treat such linked information as Personal Information.
We collect Personal Information from:
Below is a description of the Personal Information we collect, the likely source of the Personal Information, how we may use it, and for what purposes and pursuant to what legal basis.
|Use of your Personal Information||Categories of Personal Information we process||Source of the Personal Information||Legal Basis|
|Register for a service||Contact Information and other information you provide, such as your topic preferences and areas of interest||You||Legitimate interests: To enable your registration Contract: As may be described on the registration page|
|Obtain your subscription preferences and send eNewsletters and similar marketing communications||Contact Information and other information you provide, such as your topic preferences and areas of interest||You||Legitimate Interest: To provide you with information you need and other services you request and to efficiently communicate with you|
|Respond to inquiries and fulfill requests||Contact Information and other information you provide, such as your requests||You||Legitimate Interest: To provide you with information you need and other services you request and to efficiently communicate with you
Consent: We will send you marketing communications by email and text/SMS pursuant to your consent
Contract: If you are a customer or prospective customer
|Fulfill purchases and other paid services||Contact Information, Financial Information, and other information you provide, such as your preferences or areas of interest||You||Contract: To maintain your order/purchase history to fulfill orders, ensure proper delivery, or provide other services related to your purchases.
Note: We use a third party payment processor to collect and process your credit card information. We do not collect, access, store or process any credit card information related to your online transactions.
|Conduct surveys and questionnaires||Contact Information and other information you provide, such as your survey answers||You||Legitimate interests: To evaluate and take action with regard to your feedback and comments about our services
Contract: If you are our customer or prospective customer
|Register for online and in person events and deliver event-related materials||Contact Information other information you provide, such as your preferences for the event||You||Legitimate interests: To enable your attendance at our events and to deliver you event materials
Contract: As may be described on the registration page for the event
|Obtain current contact data and update contact records in our CRM||Contact Information and other information you provide, such as your relationships to people at IDEAL||You and public sources, such as LinkedIn||Legitimate interests: To ensure the integrity of our customer and other contact data|
|Perform website analytics||Online Identifiers, Demographic Information, and other information we collect, such as interests, behavior tracking, event tracking||First and third party analytics cookies||Legitimate interests: To understand more about our website visitors (what pages you view, how long you visit, your devices, etc.) in order to improve our services|
|Deliver online advertising||Online Identifiers, Demographic Information, and other information we collect, such as interests, behavior tracking, event tracking||First and third party analytics cookies||Legitimate interests: To understand more about our website visitors in order to deliver relevant advertisements|
|Recruit personnel||Contact Information, Recruitment Information, and other information relevant to potential recruitment by IDEAL, such as your resume, any cover letter/application, work history, qualifications, and reference information.||You, your references, your former employers, and public sources||Pre-contractual Measures: To recruit and evaluate potential candidates to join IDEAL
Legal obligations: To comply with applicable legal obligations, including in the field of employment law
Legitimate interest: To make the best recruitment decisions for our business
|Obtain and review security footage||Image||You||Legitimate interests: To ensure the security and safety of our facilities.|
If we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide us with the information when requested, we may not be able to perform the contract we have, or are trying to enter into, with you. We will inform you of any mandatory Personal Information we require from you and the consequences if you fail to provide it.
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and Internet activities. We use the following types of cookies on our Online Services:
A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org. We refer to cookies, web beacons, and other similar technology as “Data Collection Technology”. Data Collection Technology enables us to remember your password for future log-ins, compile statistics about use of the Online Services, and detect and prevent fraud. Data Collection Technology also helps us and our ad management partners manage our online marketing program and deliver ads that are relevant or may be of interest to you.
IDEAL participates in the Adobe Marketing Cloud Device Co-op to better understand how you use our Online Services across the various devices you use, and to deliver tailored promotions. Go to https://cross-device-privacy.adobe.com to learn more about how Adobe does this and to manage your choices relating to this linking of devices.
Our policy on “Do Not Track” signals: California’s Online Privacy Protection Act requires website operators to disclose how they respond to web browser’s “Do Not Track” (“DNT”) signals. Some web browsers incorporate a DNT or similar feature that signals to websites that a user does not want to have his or her online activity tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including IDEAL, do not respond to DNT signals.
Interest-Based Advertising. Interest-based advertising is a way that helps companies provide you with more relevant advertising on the websites you visit of the applications you use. If you want to “opt out” of receiving online interest-based advertisements, please follow the instructions at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. An “opt-out” cookie will be placed on your device indicating that you do not want to receive interest-based advertisements. Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on the Online Services. It means that the online ads that you do see will not be based on your particular interests. If you delete cookies on your device, generally you will need to opt-out again. More information about online behavioral advertising can be found at www.aboutads.info.
We may share Personal Information as follows:
Our services, including our Online Services, are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act and similar rules in other jurisdictions, if we learn that we have received any Personal Information directly from a child under age 16, or such other age as set by the laws of jurisdictions where we operate without his or her parent’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services and subsequently we will delete that Personal Information.
We implement appropriate technical and organizational measures designed to ensure your Personal Information in protected from unauthorized access, use, disclosure, alteration or destruction, in accordance with applicable laws and regulations. For example, we limit access of your Personal Information to authorized parties, periodically inspect, assess, and evaluate the effectiveness of our technical and organizational measures designed to ensure the security of our processing, and limit our collection and use of your Personal Information to the extent necessary to provide you with our services.
We will keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and all applicable legal requirements.
Opting out of our collection of your Location Information: If you do not want us to collect Location Information from your device, please delete our mobile application or disable your device’s location settings. Please note that disabling the location setting may affect certain features of the mobile application.
Maintaining the Accuracy of your Personal Information: We must ensure that your Personal Information is accurate and up to date. Please advise us of any changes to your Personal Information by contact using the information in the “How To Contact Us” section below.
Rights of Individuals in the European Economic Area: If you are located in the European Economic Area, you have the following rights with regard to your Personal Information:
Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the services we offer.
You always have the right to lodge a complaint with your local competent supervisory authority or any authority that applies to IDEAL.