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Effective Date: May 29, 2020.
2. What Data We Collect.
The information we collect from users helps us to personalize your experience, improve our Website, and improve the effectiveness of our initiatives and programs promoting U.S. cotton fiber and manufactured cotton products around the globe. Some of the information that you may enter on the Website includes personal information. Unless defined differently by applicable law, “Personal Information” is any information that personally identifies you or from which you could be identified either directly or indirectly. The Personal Information that we collect from you depends on the nature of your interaction with us and the Website, and may include the following:
A. Information You Give Us.
We receive and store any information you voluntarily enter on the Website or otherwise provide to us directly. The Personal Information that we may collect directly from you includes:
· Contact Information, such as first and last name, shipping address, and email address;
· Geolocation Information, such as country of residence;
· Preferences, such as preferred language, email subscription preferences, or an expressed interest in a particular type of cotton or cotton product; and
· Social Media Information, such as when you engage with us on social media through hashtags or by using the social media features provided on the Website (see “Third Party Services, Features, and Devices” for more information).
You can choose not to provide the Personal Information that we request, but then you might not be able to take advantage of some of the features of the Website, such as receiving personalized information directly from us.
The privacy laws of some countries place restrictions on the collection and use of Sensitive Personal Information, as defined below. We will not request Sensitive Personal Information from you and ask that you do not provide such information to us. Subject to applicable law, “Sensitive Personal Information” generally refers to personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, sexual life or judicial data (including information concerning the commission or alleged commission of a criminal offence). In some instances, it may also refer to financial information.
B. Information Collected Automatically.
We receive and store certain information whenever you interact with our digital assets, including the Website, content served on our behalf on third party websites, or emails from us. Some of this information is collected by using “Automatic Data Collection Tools,” such as cookies, web beacons, and embedded web links. The information collected in this manner includes: IP address, browser type, operating system, referring URLs and information on actions taken or interactions with our digital assets. In addition, some of our service providers may collect information about your online activities over time and across third party websites using Automatic Data Collection Tools.
The Automatic Data Collection Tools that are used on the Website and the information collected by these tools include:
· Log Information: Log information is data about your use of the Website, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.
· Browsing Information: Browsing information is information about your interactions with the Website or emails, including information about your browsing behavior. Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, and other tracking technologies now and hereafter developed may be used on the Website to collect browsing information. These Automatic Data Collection Tools are described more fully below:
· Web Beacons: Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and email messages. Web beacons may be used to count the number of visitors to the Website, to monitor how users navigate the Website, and to count content views.
· Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Website. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the website and deleted or deactivated thereafter.
· Location-identifying Technologies: Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
C. Information from Other Sources.
3. Use of Information.
We collect and use your Personal Information to manage our relationship with you, improve our programs and services, and personalize your interactions with us. Examples of how we use your Personal Information and anonymized information collected via Automatic Data Collection Tools include:
· Improving Member and Non-Member Experience: managing the Website and services we provide you, including your email subscriptions; corresponding with you, including, to respond to your requests, comments, and questions, connect you with our local program representatives, or to provide member and nonmember services to you; publishing business directories (which may include business contact information); and facilitating the functionality of our Website and any other digital assets;
· Administrative Communications: sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
· Research and Innovation: evaluating and improving the activities of our organization, including developing new initiatives, programs, and services; managing our communications; analyzing the effectiveness of and optimizing our outreach campaigns; analyzing our initiatives, programs, services, Websites, and any other digital assets. This may include the use of third-party web analytics services on our Website, such as those of Google Analytics. The analytics providers that administer these services use Automatic Data Collection Tools to help us analyze how visitors use our Websites, which allows us to better serve you;
· Compliance with Law: complying with applicable laws and regulations or requests by any judicial process or governmental agency having or claiming jurisdiction over CCI and NCC, including tracking and recording consent to the use of Automatic Data Collection Tools;
· Operation of our Organization: conducting ordinary business operations, and complying with industry standards and our policies;
· Direct Marketing: sending you outreach materials we think you may be interested in, including by email where you have consented to receive emails from us and delivered on our behalf over third-party websites. This involves the use of Automatic Data Collection Tools and sharing some of your information with marketing service providers and digital marketing networks in order to present content to you on our behalf other third party websites (for information about how to manage these communications and marketing efforts, please see Your Rights and Choices below);
In general, we will use your information for any purpose allowed under applicable laws or in support of the above purposes. We will also use Personal Information to fulfill any other purpose disclosed at the time you provide Personal Information.
4. Sharing of Information.
· With our Service Providers: Our service providers may receive or be given access to your Personal Information in connection with their work on our behalf. These service providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
· Compliance with Law or Protection of Life or Property: We may share your Personal Information to comply with the law or other legal processes, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your Personal Information to protect the rights, property, life, health, security and safety of CCI, NCC, the Website or any third party;
· Corporate Transactions: We may share your Personal Information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets, or in connection with a transfer of all or a portion of our organization to another;
We may share aggregated information which does not identify you, anonymized information collected via Automatic Data Collection Tools, or de-identified information about you with our affiliates, organizational partners, or other third parties for any purpose, including direct
marketing purposes (review Your Rights and Choices below for more information about limiting such uses). Aggregate statistics about traffic patterns may be used for internal review or shared with our service providers for analysis, among other things.
5. Third Party Services, Features, and Devices.
On our Website, you may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with CCI and NCC. These features, which include social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share Personal Information in accordance with their own privacy policies. We strongly suggest you review the third parties’ privacy policies if you use the relevant features. If you use one of these third-party features, both CCI/NCC and the third party may have access to and use information associated with your use of this feature. If you publicly reference CCI/NCC or our Website on one of these services (e.g., by using a hashtag associated with CCI/NCC in a tweet or post), we may use your reference on or in connection with our Website or organization, including for promotional or outreach activities.
As mentioned above, some of the Automatic Data Collection Tools used on our Website are operated by third-party service providers. For example, analytics services, such as Google Analytics, may use these tools to help us analyze how visitors use our Website and to compile statistic reports on the Website and other activities of our organization, and provide other services relating to Website activity and internet usage. Similarly, ad serving services, advertisers, and other third parties may use these tools on our Website, as well as other websites served by those entities, to collect information about your online activities over time and across third-party websites in order to customize and serve content and advertising, which may include sending you content on a third-party website or device after you have left the Trust Protocol Website.
For further information on Automatic Data Collection Tools and your choices regarding them, please see Information Collected Automatically above and Your Rights and Choices below.
6. Your Rights and Choices.
a. Accessing Your Information.
You may access, update, or remove certain Personal Information that you have voluntarily submitted to us through the Website by sending us an email here with the words “PRIVACY
RIGHTS REQUEST” in the subject field of the message. We may require additional information from you to allow us to confirm your identity.
b. Data Storage and Retention.
Personal Information that we maintain is stored on our servers. We will retain your Personal Information for as long as is necessary to provide you services and to achieve the purpose(s) for which such data is collected. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
c. Controlling Cookies.
We use both First-Party and Third-Party Cookies on our Website. Cookies set by a website owner (in this case CCI/NCC) are called “First Party” Cookies. Our First Party Cookies are limited to functional Cookies that improve the usability of the Website. Specifically, one of our First Party Cookies attaches when you first select a language on our site and sets and stores your language preference, and another remembers whether or not you have viewed and accepted, where applicable, the Website’s introductory privacy pop-up.
Cookies set by parties other than the website owner are called “Third Party Cookies”. Third Party Cookies belong to and are managed by other parties, such as CCI business partners and service providers for advertising, analytics and other purposes. The following Third-Party Cookies are used on the Website:
· Google Analytics
· The Trade Desk
· Salesforce DMP
· Salesforce DMP User-Match Pixels:
o AdRoll User Match
o DataLogix – Legacy
o DataXu User Match
o eXelate Media
o Google User Match
o LiveRamp Data Matching
o MediaMath User Match
o Neustar AdAdvisor S2S
o TheTradeDesk User Match
o TubeMogul User Match
o Visual DNA
Cookies generally may be disabled or may be removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options; so you may need to set them separately. To find out more about cookies and how to block them or control their use by configuring your browser you can visit www.allaboutcookies.org. For more information on the use of targeting/advertising cookies, please see www.youronlinechoices.eu if you are located in Europe or www.aboutads.info/choices if in the United States.
If you want to remove previously stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Website from placing further Cookies on your device, either during an ongoing session or upon your next visit to the Website, unless and until you adjust your browser setting to not accept cookies, and provided your browser has this functionality. For users whose data is protected by the GDPR, you can prevent the Website from placing further Cookies on your device by clearing all cached content from your browser, in which case further Cookies will not be placed on your device unless and until you click the “I Accept” button again on our introductory privacy pop-up.
Please be aware that some parts of the Website may not function properly if you disable or remove cookies and that when you revisit the Website, your ability to limit browser-based cookies is subject to your browser settings and limitations as described above.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
d. Controlling Automatic Data Collection Tools for Analytics and Direct Marketing.
You may exercise choices regarding the use of Automatic Data Collection Tools from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
You may exercise choices regarding receipt of interest-based advertising by submitting opt outs. Some of the advertisers and service providers that perform marketing-related services for us may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about DAA how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices. Some of these companies may also be members of the Network Advertising Initiative
(“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain internet-based advertising to you, and it does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). CCI/NCC are not responsible for the effectiveness of, or compliance with, any third parties’ opt out options or programs or the accuracy of their statements regarding their programs.
You can opt out of receiving certain promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or contacting us here with the word UNSUBSCRIBE in the subject field of the message.
f. Access to and Modification of Personal Information
In some jurisdictions, you may have the right to access or modify your Personal Information, including the right to: obtain confirmation that we hold Personal Information about you, request access to and receive information about the Personal Information we maintain about you, receive copies of the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, object to the processing of your Personal Information, and have the information blocked, anonymized or deleted, as appropriate. These rights are only available if you reside in, or access the Website from, certain jurisdictions and may be limited in some circumstances by the local laws and regulations in those jurisdictions or others. To exercise these rights, please email us here or send us a letter to: Cotton Council International, Worldwide Headquarters, 1521 New Hampshire Ave., NW, Washington, DC 20036. Requests must include “PRIVACY RIGHTS REQUEST” in the subject field of the message and include your name, street address, city, state/province, postal code and country. This information will be used to communicate with you regarding your request and verify the applicable jurisdiction. Please note that in some jurisdictions where the above rights apply CCI and NCC are not required to respond to requests made by means other than through the email address or mail address provided above.
The Website is intended for a general audience and is not directed to children under thirteen (13) years of age. We do not knowingly collect Personal Information from children under 13. If you are a parent or guardian and believe we has collected Personal Information from a child under 13, please email us here with the words ’PRIVACY RIGHTS REQUEST” in the subject field of the message or send us a letter to: Cotton Council International, Worldwide Headquarters, 1521 New Hampshire Ave., NW, Washington, DC 20036, and we will take steps to delete that information.
8. Data Security.
We take reasonable measures to help protect Personal Information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through our Service.
11. Contact Us.