This Policy was last updated on June 30, 2020.
What processing activities are covered?
This Policy applies to the processing of personal information when you:
- Visit our website, freedomforum.org (the “Site”);
- Receive communications from us, including emails, phone calls, faxes, texts, video chats, etc.;
- Complete surveys from us; and
- Request information from us online.
Who is responsible for your personal information?
If you are a user in the European Union (the “EU”) or European Economic Area (“EEA”), for purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), we act as a data controller with respect to the personal information described in the “What Personal Information Do We Collect” section of this Policy. In this role, we are responsible for implementing the applicable data protection principles and for safeguarding personal information.
How Do We Process Personal Information?
What Personal Information Do We Collect?
We may collect and process the following personal information from you for the purposes set forth below, including in the “Other Processing Activities” section of this policy:
|Category||Description and Purpose|
When you visit our Site, request our services, or register for events or programs with us, we may ask you for your name, address, telephone number, email address, or other contact details in order to respond to your request or inquiry.
|Cookies and Similar Technologies||
When you visit our Site, we collect cookies and use similar technologies to enhance your experience, gather general visitor information, and track visits to our Site, all in order to provide you with a more personal and interactive experience on our Site, to improve our marketing efforts, and for usage analytics purposes (e.g., page response times, download errors, length of visit, webpages visited, etc.).
Please see our Cookies and Similar Technologies Policy for more information. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly.
We process Cookies and Similar Technologies to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, and to improve our marketing efforts. We rely on your express opt-in consent for the use of analytic or marketing cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Site and business.
When you visit our Site, we automatically collect information from your browser or your device, which includes the date and time of your visit, your Internet Protocol (IP) address or unique device identifier, your browser type, cookies and data about which pages you visit in order to allow us to operate and provide the Site and our services. When you use our Site, we may collect information about your use of our Site, including your interaction with certain aspects of the Site. To learn more about our collection of technical data, please see our Cookies and Similar Technologies Policy.
We process Usage Information to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, and to provide you with a more personal and interactive experience on the Site. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services.
|Your Communications and Feedback||
If you provide us with feedback or contact us for support or to ask us questions, we will collect your name, address, telephone number, email address, organization/affiliation, message, and other information needed to respond to your feedback or request for support, or to answer your question. When you communicate with us, we may retain your communications in order to process and respond to them, as well as to improve our services. We may use your email address to communicate with you about our services or send you periodic emails if you decide to sign up for one of our newsletters.
If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message and click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts. We do not sell or distribute this information to third parties.
If you want to make a comment on a blog post on the Site, we will collect your name, email address, Site, and your comment.
When you sign up for one of our mailing lists or newsletters, we collect your contact information, including your name, address, telephone number, and email address.
|Sensitive Personal Information||
We may collect information regarding your racial or ethnic origin, gender, citizenship status, political opinions, religious or philosophical beliefs, financial information, or data concerning your sexual orientation. We will collect this personal information with your express consent or as otherwise permitted by applicable law.
We process Sensitive Personal Information to analyze use of our services, to serve you the content and functionality you request, to ensure the privacy and security of our services, to develop new services, to enhance your experience, and for surveys and applications that are consistent with our organizational mission. The legal basis for this processing is your consent.
|Third Party Information||
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly-available sources.
We process Third Party Information to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, to provide you with a more personal and interactive experience on the Site, and for usage analytics purposes. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services.
Is entry of Personal Information required?
You may choose not to provide us with any personal information. Even if you choose not to provide any personal information, you may still access and use much of the Site. However, you will not be able to access any portions of the Site that require your personal information. Some pages on the Site may give you the option of providing certain of your personal information about yourself. If you want to change any information about yourself that you have submitted, you may contact us via the “Contact Us” details at the end of this Policy.
Other Processing Activities
Other GDPR Processing Activities
We may process any of the personal information identified in this Policy when necessary for:
- The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for such processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
- Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)
- Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.
We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
- Because it is necessary to perform the services you have requested or to comply with your instructions or other contractual obligations between you and us;
- To comply with our legal obligations as well as to keep records of our compliance processes;
- Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
- Because you have chosen to publish or display your personal information on a public area of the Site, such as a comment area;
- Because it is necessary to protect your vital interests;
- Because it is necessary in the public interest; or
- Because you have expressly given us your consent to process your personal information in a particular manner.
We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.
Other U.S. Processing Activities
Where the GDPR does not apply, in addition to the processing described above, we may use your personal information in order to:
- Operate our business and the Site;
- Provide you with the services, products, content, and functionality you request;
- Honor our contracts;
- Manage our relationship with you;
- Process payments and other transactions;
- Maintain our databases and back-ups, including records of our communications with you;
- Obtain and maintain insurance for our business;
- Ensure the privacy and security of the Site and our services;
- Detect fraud and prevent loss;
- Support and improve the Site, including evaluations of functionality and features;
- Improve our customer service (your information helps us to more effectively respond to your customer service requests and support needs);
- Communicate with you and respond to your feedback, requests, questions, or inquiries;
- Promote our products and services to you (we will only provide you with marketing-related information after you have, where legally required to do so, opted in to receive those communications and having provided you with the opportunity to opt-out of such communications at any time);
- Contact you about other products and services;
- Conduct research and analysis;
- Improve our products and services and develop new products and services;
- Improve our marketing efforts, including by providing more tailored advertising;
- Administer a contest, promotion, or survey (we may periodically run a contest, sweepstakes, or survey, and, when we do so, it will be accompanied by a set of rules that specify how the information gathered from you for entry will be used and disclosed);
- Recognize your device and remember your interactions;
- Provide you with a more personal and interactive experience on the Site;
- Analyze use of the Site and prepare aggregate traffic information;
- Determine and track user interests, needs, and preferences;
- Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transfers;
- Accomplish any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your personal information was provided to us;
- Accomplish another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law;
- Comply with federal, state, or local laws;
- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, summons, or order by federal, state, or local authorities;
- Cooperate with law enforcement agencies;
- Exercise or defend legal rights or claims; and
- Create, use, retain, or disclose de-identified or aggregated data
How Do We Share or Disclose Your Personal Information?
When we are acting as a data controller and where the GDPR does not apply, we may share your information in the following contexts.
|Affiliates||We may share your personal information with our subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents.|
|Acquisitions and Similar Transactions||We may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.|
|Disclosures with Your Consent||We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We may also provide personal information about you to third parties that may offer products and services specifically requested by you. We will only disclose your personal information in this context with your consent.|
|Legal Obligations and Rights||We may disclose your personal information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to defend against a legal claim, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts. We may also disclose personal information as needed to protect vital interests.|
|Public||Some areas of our Site, including our blog, may offer forums or provide the opportunity for users to post comments or reviews in a public forum. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information. If you decide to submit your personal information in these areas, you do so at your own risk and acknowledge that the information will be publicly-available.|
|Service Providers||We may share your personal information with our service providers that need access to your information to provide operational or other support services on our behalf. Among other things, service providers help us to administer the Site; support our provision of services requested by you; provide technical support; send marketing, promotions and communications to you about our services; provide payment processing; and assist with other legitimate purposes permitted by law.|
|Professional Advisors||We may share your personal information with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.|
|Deidentified or Aggregated Data||We may disclose aggregated information about our users and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for new service and marketing development.|
How Long Do We Store And Use Your Personal Information?
We will retain and use your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.
We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives.
To the extent permitted by law, we may retain and use anonymous or aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. When we delete personal information, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it.
How Do We Protect Your Personal Information?
We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, or disclosed or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technology and methods.
While our security measures seek to protect your personal information in our possession, no security system is perfect, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you do so at your own risk. We cannot promise that your personal information will remain absolutely secure in all circumstances.
The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.
If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.
Rights and Choices About How We Use and Disclose Your Information
Please use the “Contact Us” details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or if you no longer want to receive any email, postal mail, or telephone contact from us in the future, such requests may be submitted via the “Contact Us” details at the end of this Policy.
If you no longer wish to receive communications from us via email, you may opt-out by clicking the unsubscribe link available at the bottom of our emails or by contacting us at [email protected] and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take action.
You may choose to not allow analytic cookies via the cookies consent banner or set your browser to refuse all or some browser cookies or to alert you when cookies are being set. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/. Please see our Cookies and Similar Technologies Policy for more information.
Online Tracking Signals
We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on the Site or on third-party Sites or online services where we may collect information.
Accuracy and Updating Your Personal Information
Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
If you wish to change your communication preferences or ask that we restrict how we use your personal information, please contact us via the “Contact Us” details at the end of this Policy. You may follow opt-out links on any marketing communications sent to you.
If you believe that your rights relating to your personal information have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details provided at the end of this Policy.
Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at [email protected].
You may submit a verified request to us at [email protected] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.
If you are located in the EU or EEA, you have the following rights under the GDPR. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.
Right of Access
To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.
Right of Rectification
Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
Right to Erasure
In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases as well as the Site; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
Right to Restrict Processing
You have the right to restrict the processing of your data when (1) the accuracy of the personal data is contested, for a period enabling us to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the personal data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the personal information, pending resolution of the objection.
Right to Object
In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.
Right to Withdraw Consent
If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
Right to Complain
If you believe we have not processed your personal information in accordance with applicable provisions of the GDPR, we encourage you to contact us at [email protected]. You also have the right to make a GDPR complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.
International Transfers Of Personal Information
We are located and established in the United States and, therefore, your personal information may be transferred to, stored, or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the privacy and security of your personal information. By using the Site or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy.
When storing, hosting, or otherwise processing your information (including personal data), we may send such data outside of the European Union (EU) and the European Economic Area (EEA). When we transfer information to the United States or other countries, we do so for the purposes set forth in this Policy and in accordance with applicable law. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information outside of the EU and EEA, such as your express informed consent to do so (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement between us and you, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.
This Policy is applicable only to the Site, and it does not apply to any third-party websites.
The Site may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we have no relationship. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third party Sites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party Site. You can check the URL to confirm that you have left this Site.
We cannot and do not (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their Sites, (ii) control third parties’ independent collection or use or your personal information, or (iii) endorse any third-party information, products, services or Sites that may be reached through embedded links on this Site.
Children’s Online Privacy Protection Act
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 13 or younger, nor is information knowingly collected from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or provide any information to or on the Site. If you are under 13, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 13, please contact us using the contact information provided below.
For more information about COPPA, please visit the Federal Trade Commission’s Site at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
Updates and Changes to This Policy
We reserve the right, at any time, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your personal information or in response to changes in law. Should this Policy change, we will post all changes we make to this Policy on this page. If we make material changes to how we treat your personal information, we will also notify you by posting a notice on the homepage of the Site for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting on the Site. The date on which this policy was last modified is identified at the beginning of this Policy.
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your personal information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of the Site.
For more information, or if you have any questions or concerns regarding this Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.
In writing: 300 New Jersey Avenue NW, Suite 800, Washington, DC 20001
By phone: (202) 292-6100
By email: [email protected]