91proÊÓƵ

Effective Date: May 25, 2018

The 91proÊÓƵ ("91proÊÓƵ," “we,” “our,” or “us”) has developed this policy statement to assist you in understanding why 91proÊÓƵ collects particular personal identifying information and how 91proÊÓƵ will protect your personal privacy within its Web site (the "Privacy Policy").

The following information summarizes our personal identifying information gathering and dissemination practices for the 91proÊÓƵ's United States Web site located at the URL, www.itic.org, and any other site provided by 91proÊÓƵ (collectively, the "Site"). Personal identifying information includes information that can be linked to a specific individual, such as a name, address, phone number, or e-mail address.

91proÊÓƵ reserves the right to change this Privacy Policy at any time. If 91proÊÓƵ makes changes to this Privacy Policy, 91proÊÓƵ will post those changes at this location and provide you with notice of any material changes so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Please review this Privacy Policy on a periodic basis.

For purposes of this Privacy Policy, references to "91proÊÓƵ" shall also include .

What Information Does 91proÊÓƵ Collect?

PLEASE NOTE: THE TYPE OF DATA COLLECTED BY 91proÊÓƵ WILL VARY WITH YOUR USE OF THE SITE.

To improve the quality of the products and services 91proÊÓƵ offers to you and to operate the Site, 91proÊÓƵ collects various personal identifying information (as described below) from different parts of its Site. 91proÊÓƵ gathers most information during the registration process to use 91proÊÓƵ's services and products. But, 91proÊÓƵ 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 91proÊÓƵ, and when you post information on the Site.

Below, we provide examples of the types of personal identifying information 91proÊÓƵ collects through the Site. Again, please be aware that the type of data collected by 91proÊÓƵ will vary with your use of the Site.

Contact Information: 91proÊÓƵ requests or requires contact and other personal identifying information, such as your name, address, phone number, facsimile number, and e-mail address.

Demographic Information: 91proÊÓƵ collects demographic and profile data (for example, job title, job position, and technical computer or Internet connection information) at our Site for management and monitoring purposes and to improve the quality of 91proÊÓƵ's services. In addition, 91proÊÓƵ collects demographic and profile data in connection with surveys it conducts for its own internal administration purposes or for release to third parties.

Transactional Information: 91proÊÓƵ maintains a database of aggregated information about the transactions on the Site (e.g., offer/request data, product/service categories, and product/service prices).

Technical Information: 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 two different levels of service: (1) a members only section (the "Members Only Section"); and (2) publicly available information areas. Consequently, until you register to access a Members Only area, you are able to browse the Site without providing any personal identifying information. In particular, you do not need to register with 91proÊÓƵ or submit any personal identifying information to view information in those sections of the Site that are publicly accessible, such as the About 91proÊÓƵ, Public Policy and Newsroom 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.

Only the Members Only Section requires that you register with 91proÊÓƵ. Accordingly, if you wish to become a member, you will need to agree to provide your personal identifying information to be used as discussed below. In addition, if you wish to receive information from 91proÊÓƵ, order products and services from 91proÊÓƵ, be included in the 91proÊÓƵ member directory, and/or participate and receive the results of surveys, then 91proÊÓƵ will need to receive your personal identifying information, and in particular, your name and e-mail address for communication purposes. Please note, however, that the 91proÊÓƵ 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 91proÊÓƵ, you share that information only with 91proÊÓƵ, unless (i) you are using 91proÊÓƵ's services as a part of a third party Web site (in which case information sharing between such third party and 91proÊÓƵ will take place in order for the third party to offer 91proÊÓƵ's services); (ii) you are completing a transaction involving third party services, such as viewing the 91proÊÓƵ scorecard through CapWiz, 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 91proÊÓƵ uses your personal identifying information.

How Does 91proÊÓƵ Use and Share That Information?

Contact Information: 91proÊÓƵ may use your contact information to provide its goods and services, to share your information with others as a part of the Members Only on-line directory, to advertise its goods and services and the goods and services of third parties, to create a personalized experience for you, to provide you with news and information, to contact you regarding a survey, to complete a transaction for goods and services, 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 91proÊÓƵ 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: 91proÊÓƵ 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 and initiatives.

Technical Information: We use technical information, such as your IP address or browser type, to help diagnose problems with our servers, analyze Site usage trends, track user movements on the Site, and to otherwise manage and monitor our Site.

Business Partners: 91proÊÓƵ has partnered with reputable third parties, such as CapWiz, to offer you a variety of 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, 91proÊÓƵ wishes to remind you that such third parties may have different privacy policies and practices than 91proÊÓƵ. 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: 91proÊÓƵ relies on third party service providers to store and process data on its behalf.

Business Transactions: In the event that 91proÊÓƵ goes through a business transaction, such as a merger, acquisition by another company, or sale of all or a portion of its assets, please note that the personal identifying information collected and retained by 91proÊÓƵ will be among the assets transferred. In the event a transaction of this kind occurs that results in the transfer of personal identifying information, 91proÊÓƵ will notify you via e-mail and place a prominent notice on the Site for 30 days of any such change in ownership or control and the possible changes to this Privacy Policy.

What About the Use of Cookies?

91proÊÓƵ may use cookies to enhance your experience while using our Site. Cookies are pieces of information, which 91proÊÓƵ uses for record-keeping purposes, which the Site transfers to your computer's Web-browser for storage on your computer's hard drive. Cookies enable 91proÊÓƵ to customize your experience on the Site. Cookies also make Web-surfing easier by automatically performing certain functions such as saving your personal preferences and by ensuring that you don't see the same advertisement repeatedly. 91proÊÓƵ, however, will not use cookies to record passwords or credit card or other financial information. Moreover, you can delete any cookies residing on your hard drive by following the instructions for your Web browser.

Many consider the use of cookies to be an industry standard. Consequently, your Web browser is likely set to accept cookies. If you would prefer not to receive cookies, however, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, you should understand that it is possible that some areas of our Site will not function properly when you view them.

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 .

We do not use automatic decision-making or engage in profiling.

What About External or Third Party Web Sites?

To the extent hyperlinks or gateways are utilized to access external or third party sites, you should be aware that these external or third party sits are not controlled by 91proÊÓƵ and therefore, are not subject to this Privacy Policy. 91proÊÓƵ suggests that you check the privacy policies of these sites to determine how the proprietors of these third party sites will utilize your personal identifying information.

International Visitors

This section applies to those that visit our Site from the European Economic Area (EEA) or Switzerland.

Lawful Basis for Processing

On most occasions, 91proÊÓƵ may process personal data with the individual’s consent (e.g., when a Site visitor agrees that 91proÊÓƵ may place cookies, or process information that Site visitor inputs into the Site).

On other occasions, 91proÊÓƵ may process personal data when we need to do this to fulfil a contract (for example, for billing purposes) or where 91proÊÓƵ is required to do this by law.

If necessary, 91proÊÓƵ may also process a Site visitor’s data when it is in 91proÊÓƵ’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 “Contact Us” section below for contact information.

Transfers of Personal Data

Please be aware that the personal data we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. If you are located outside of the United States, please be advised that we process and store personal data in the United States and your consent to this Privacy Policy represents your agreement to this processing.

Your Rights

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 “Contact Us” section below. Please be aware that 91proÊÓƵ 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.

Retention

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. 91proÊÓƵ 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 91proÊÓƵ 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 [insert other criteria used to determine storage period for data that does not have a statutory retention period]. 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 or the initiation of a contract.

What About Security?

91proÊÓƵ places a premium on making sure that personal identifying information remains private and secure and is not subject to misuse or manipulation. Accordingly, this Site has industry standard security measures in place, including storage of personal identifying information in a secure environment, to protect against the loss, misuse, and alteration of the information under 91proÊÓƵ's control. Although 91proÊÓƵ has endeavored to create a secure and reliable Site, 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. 91proÊÓƵ urges you to take every precaution to protect your personal identifying information when on-line.

What Are My Choices Regarding Data Collection and Use?

The collection, use, and distribution of your personal identifying information is necessary for 91proÊÓƵ 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 91proÊÓƵ its products will need to agree to 91proÊÓƵ's use and collection of personal identifying information.

But, a number of 91proÊÓƵ's other programs are completely voluntary and you can decide on your own if you wish to participate or opt-out. For example, if 91proÊÓƵ conducts a survey, you do not have to participate unless you agree to do so and provide your e-mail address in order for 91proÊÓƵ to communicate with you.

91proÊÓƵ also provides you with the opportunity to opt-out of certain 91proÊÓƵ business practices where your personal identifying information may be used. Specifically, users my opt-out of including the personal identifying information they provide to 91proÊÓƵ in connection with the following activities: (i) inclusion on the 91proÊÓƵ member directory, (ii) inclusion in member mailings, (iii) e-mail communications sent by 91proÊÓƵ, (iv) facsimile communications sent by 91proÊÓƵ, and (v) lease, rental, or sharing arrangements with 91proÊÓƵ's business partners (when not done for the purpose of concluding e-commerce transactions that you execute with 91proÊÓƵ for its products and services).

Thus, to a large extent, you can control the information you provide or share with 91proÊÓƵ and/or its business partners. Moreover, even when 91proÊÓƵ contacts you, from time to time, regarding its products/services, this Site, or otherwise, if 91proÊÓƵ sends you such a communication, 91proÊÓƵ specifically provides you with the opportunity to opt-out of receiving similar future correspondence by sending an e-mail to info@itic.org.

What About Correcting, Deleting, or Updating Information?

At any time, you may contact 91proÊÓƵ to correct, modify, or delete the information you provide to 91proÊÓƵ 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@itic.org with any requests or changes. Moreover, when you cease to use 91proÊÓƵ's services and no longer wish to be included in 91proÊÓƵ database, you may contact 91proÊÓƵ at info@itic.org to request to have your information removed from our database. In the event that 91proÊÓƵ receives such a request or change, 91proÊÓƵ 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 91proÊÓƵ's ability to provide it inoperable.

Contact Us

If you have any questions about this Privacy Policy, the information collection and dissemination practices of this Site, or 91proÊÓƵ's use of your personal identifying information, you can contact 91proÊÓƵ in our role as data controller, at 1101 K Street NW, Suite 610, Washington, DC 20005, 202-737-8888, or info@itic.org.

For visitors from the EEA, to contact our representative, please use the contact information above.