TIA Privacy Policy

Effective Date: May 25, 2018

Background:

TIA understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site AND You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

  1. Definitions and Interpretation
    In this Policy the following terms shall have the following meanings:
    “Account”means an account required to access and/or use certain areas and features of Our Site;
    “Cookie”means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
    “Our Site”means this website, tiaonline.org and tiafotc.org;
    “US and EU Cookie Law”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
    “We/Us/Our”means TIA (Telecommunications Industry Association), an Illinois non-profit corporation, whose registered address is 1320 North Courthouse Road, Suite 200 Arlington, VA 22201.
  2. Information About Us
    1. Our Site is owned and operated by ourselves
    2. Our data protection officer is Andy Kurtzman who can be contacted at AKurtzman (at) tiaonline (dot) org
  3. Scope – What Does This Policy Cover?
    This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
  4. What Data Do We Collect?
    Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of Cookies) other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:
    1. Name;
    2. date of birth;
    3. gender;
    4. business/company name
    5. job title;
    6. profession;
    7. contact information such as email addresses and telephone numbers;
    8. demographic information such as post code, preferences and interests;
    9. financial information such as billing information
    10. IP address (automatically collected);
    11. web browser type and version (automatically collected);
    12. operating system (automatically collected);
    13. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
    14. other confidential data about your phone numbering plan
  5. How Do We Use Your Data?
    1. All personal data is stored securely. For more details on security see section 6, below.
    2. We use your data to provide the best possible products and services to you. This includes:
      1. Providing and managing your Account;
      2. Providing and managing your access to Our Site;
      3. Personalising and tailoring your experience on Our Site;
      4. Supplying Our products and services to you;
      5. Personalising and tailoring Our products and services for you;
      6. Responding to communications from you;
      7. Supplying you with email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time using the unsubscribe link at the bottom of such emails;
      8. Market research;
      9. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
      10. Fraud prevention
    3. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
    4. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
    5. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.  We will only process your personal data if at least one of the following basis applies:
      1. you have given consent to the processing of your personal data for one or more specific purposes;
      2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
      3. processing is necessary for compliance with a legal obligation to which we are  subject;
      4. processing is necessary to protect the vital interests of you or of another natural person;
      5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
      6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
  6. How and Where Do We Store Your Data?
    1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.  In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
    2. Your data may be stored or transferred in the USA. We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR.
    3. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
    4. Steps We take to secure and protect your data include:
      1. https for website access
      2. restricted use of FTP
      3. security hardening of server software
      4. regular patching of server software
      5. security audits
    5. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
    6. How long we keep information
      How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
      1. Account information: We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
      2. Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.
      3. Marketing information: If you have opted to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
  7. Do We Share Your Data?
    1. We may share your data with other companies in Our group. This includes Our subsidiaries, members and sponsors.
    2. We may contract with third parties to supply products and services to you on Our behalf. These may include software development, payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
    3. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
    4. In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
  8. What Happens If Our Business Changes Hands?
    1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
    2. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
  9. How Can You Control Your Data?
    1. When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and by managing your Account).
    2. You may also wish to sign up to one or more of the preference services operating in the USA: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
  10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
    1. You may access the login page Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
    2. You may restrict your internet browser’s use of Cookies. For more information, see section 12.
    3. You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems.  However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
  11. How Can You Access Your Data?
    You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please have your organization administrator contact Us for more details by using the contact details below in section 14.
    Children
    The Services are not directed to children (individuals under the age of 16). We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information.
  12. Cookies
    Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services.  By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for marketing and advertising.  In addition, Our Site uses analytics services provided by Google, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site.
  13. How to access and control your information
    Below is a summary of your choices about your data, how to exercise them and any limitations. We will respond to requests about this within a reasonable timeframe. Where the Services are administered for you by an administrator you may need to contact your administrator to assist with your requests first.
    Your Choices:
    You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format.
    Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.
    Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
    Access and update your information: Our Services give you the ability to access and update certain information about you from within the Service.
    Delete your information: Our Services gives you the ability to delete certain information about you from within it. However, we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
    Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don't have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable).
    Opt out of communications: You may opt out of receiving marketing communications from us by using the unsubscribe link within each email. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our site. You can opt out of some notification messages in your account settings. Please note, you will continue to receive generic ads.
    You may be able to opt out of receiving personalized advertisements from other companies who are members of TIA.. To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.
  14. Automated Decision-Making and Profiling
    1. 14.1   In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
    2. 14.2 The right described in section 14.1 does not apply in the following circumstances:
      1. The decision is necessary for the entry into, or performance of, a contract between the You and Us;
      2. The decision is authorised by law; or
      3. You have given you explicit consent.
    3. 14.3.Where We use your personal data for profiling purposes, the following shall apply:
      1. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
      2. Appropriate mathematical or statistical procedures will be used;
      3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
      4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
  15. Contacting Us
    If you have any questions about Our Site or this Privacy Policy, please contact Us by email at AKurtzman (at) tiaonline (dot) org, or by post at 1320 North Courthouse Road, Suite 200, Arlington, VA 22201, USA. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).
  16. Changes to Our Privacy Policy
    We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.
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