LeadingAge Privacy Notice

Effective Date: April 1, 2018

LeadingAge (“LeadingAge,” “we,” “our,” or “us”) provides this privacy notice to describe how we collect, use, share, and otherwise process the personal data of individuals that visit our website www.leadingage.org (“Site”).  To make this notice easy to find, we make it available on our homepage and where personal data may be requested.

Information Collection

We collect any information provided by you when you visit our Site, including your name, email address, phone number, payment information, and organization information.  We may collect this information when you donate to LeadingAge, apply to be our member or partner, register for our subscriptions, or provide your information to us for any other purpose.  We also use cookies and similar technologies to collect information such as your IP address, the browser used to access the Site, the date and time of visit, the URL of the page being loaded, users who have visited a particular website, any previously assigned cookie identification, browser window size, and the geographic location of the user, device, and operating system used to access the Site.  We may use this information for advertising and other purposes. See the Digital Advertising & Analytics section of this privacy notice to learn more about the use of this information and the choices available to you.

The provision of personal data is sometimes required by law and at other times is a result of a contractual requirement.  You may be required to provide personal data, for example in a case where we sign a contract with you, and the non-provision of personal data could, in certain circumstances, prevent a transaction from concluding.

Information Use

We use the information we collect for any lawful purpose, including, but not limited to, the following purposes:

• To enhance the performance and functionality of the Site;
• To deliver products and services you request, such as our newsletters;
• To respond to your inquiries, or contact you as you request;
• To advertise and market our products and services;
• To process your donations and applications;
• For LeadingAge’s internal business purposes, including for analytics purposes;
• To protect the security of our interests, including our premises, assets, and systems;
• To comply with the law; and/or
• As otherwise disclosed at the time information is collected.

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

Where we intend to use or otherwise process your personal data for a purpose other than the purpose for which it was collected, we will provide you with information regarding the purpose for the processing, as well as other relevant information, prior to processing your personal data for the new purpose.

Information Sharing

We share your personal data with the following third parties:

• With third parties performing services on behalf of LeadingAge, such as website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential;
• As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
• As required to comply with the law, enforce our Site policies, or protect ours or others’ rights, property, or safety; or
• With your consent or as otherwise disclosed at the time of data collection or sharing;
• With third parties that compile information for member publications, including contact information for relevant organizations.

We may share information that has been de-identified or aggregated without limitation.

Digital Advertising & Analytics

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms.  Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Site and other sites or apps over time, including information about relationships among different browsers and devices.  This type of advertising is known as interest-based advertising.

LeadingAge adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this interest-based advertising activity.  You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program.  If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications.  It may make the ads you see less relevant to your interests. Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Site may not function as intended.

We may also work with third parties that collect data about your use of the Site and other sites or apps over time for non-advertising purposes.  LeadingAge uses Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing 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/.

Third-Party Links and Tools

The Site may provide links to third-party websites or apps, including our social media pages.  We do not control the privacy practices of those websites or apps, and they are not covered by this privacy notice.  You should review the privacy notices of other websites or apps that you use to learn about their data practices.

The Site may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties.  If you use these tools to share personal information or you otherwise interact with these features on the Site, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public.  Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.

International Visitors

This section applies to those that visit our Site from the European Union.

Lawful Basis for Processing

On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide services to you.  We may also process your personal data to respond to your inquiries concerning our products and services.

On other occasions, we process your personal data where required by law.  We may also process your personal data if necessary to protect your interests or the interests of a third party.

Additionally, we process your personal data when necessary to do so for direct marketing purposes and this interest is not overridden by your data protection rights.  Where we process your personal data for this purpose, our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
If the processing of personal data is necessary and there is no statutory basis for such processing, we will generally obtain consent from you.  You have the right to withdraw your consent to the processing of personal data at any time.

If you wish to exercise the right to withdraw consent, contact our Data Protection Officer or LeadingAge’s Controller Representative.  Visit the “Contacting 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 notice 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.

All requests will be dealt with at the earliest opportunity.  To exercise these rights, contact our Data Services Team. See the “Contacting Us” section below.  Please be aware that LeadingAge 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.

Your Opt-Out Choices

The online advertising industry provides a website from which EU residents may opt out of receiving targeted ads from our data and advertising partners. To access this page, visit http://www.youronlinechoices.eu.

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.  The criteria used to determine the period of storage of personal data is the respective statutory retention period or if there has been no transactional activity with LeadingAge for six years.  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.

Your Choices

To change your communication preferences, including to unsubscribe from our subscriptions, you can use the link provided at the bottom of each marketing message.

Updating your Information

You may request to review, change, or update your contact information by emailing us at DataServices@LeadingAge.org.

Changes to Our Policy

We may revise this policy at any time. Any changes and/or updates to the policy will be updated directly on this page. We encourage you to visit this page periodically to review our current privacy policy.

Contacting Us

If you have questions, comments, or concerns about this privacy notice, please contact us, in our role as data controller, through our Controller Representative at:

Pavel Obgolz
LeadingAge
2519 Connecticut Ave NW
Washington, D.C. 20008
pobgolz@leadingage.org