Effective as of March 26, 2019
Purpose and Scope
Because we are a global trade organization, this Policy takes into consideration the diverse network of regulations and laws throughout the world regarding the protection, collection, use, maintenance, sharing, and disposition of private Personal Information (“Personal Information”). Personal Information includes, but is not limited to, names, phone numbers, emails, Internet Protocol (“IP”) addresses, Personal identification numbers, financial account Information, and countries of origin.
Unless otherwise agreed in member agreements or other governing contracts, Personal Information will be collected, used, disclosed, and maintained by IRTA in accordance with the terms outlined in this Policy.
Where required by law, IRTA will obtain express written or oral consent for the collection, use, maintenance and disclosure of Personal Information.
Where not required by law, consent may or may not be obtained by IRTA where Personal Information is legally permitted to be collected and used without consent. Such situations include:
- the processing of Personal Information as required by law (e.g. subpoena).
- the processing of Personal Information is required as part of regulatory obligations.
- the processing of Personal Information is necessary or beneficial as part of the provision of products and services to members or for auditing, compliance, and corporate governance functions.
- if IRTA, in its sole discretion, believes disclosure of Personal Information is necessary to protect the rights, property, or interests of IRTA, its affiliates, and/or its respective members, directors, officers, employees and agents and/or the public.
- for assistance with investigations into malicious, fraudulent or unethical activity or other wrongdoing.
- for use in the aggregate without specific attribution;
- the Personal Information is otherwise publicly available.
This Policy is current as of the effective date set forth above. This Policy may be reviewed and changed over time. All modifications shall be effective as of the date set forth.
Personal Information may be collected by IRTA in connection with:
Websites. In order to better serve its members, IRTA and third parties operating on IRTA’s behalf may collect Personal Information from users of IRTA’s websites. Some of this information is collected automatically through cookies. Non-Personal Information may also be obtained from websites such as pages viewed, search terms entered, location, operating systems, browser software, preferred language and internet service providers. If non-Personal Information is linked to Personal Information, generally such non-Personal Information will be treated as Personal Information. IRTA websites may also contain links to third party websites which IRTA does not control and may be governed by different privacy policies and practices. IRTA is not, and will not be, responsible for the privacy policies or practices of third parties or the content or security of any third-party websites.
Public Forums. Posts, comments or other information submitted on any public forums (e.g. website comment sections, message boards, social media, blogs, chat rooms), including those created by IRTA, are not private or confidential. IRTA may use any such content and data (“Postings”), any content thereof and any information derived therefrom (including any ideas, concepts, know-how or other intellectual property), as deemed appropriate by IRTA in its sole discretion. Additionally, IRTA shall have no responsibility for how others use any Postings in IRTA sponsored public forums and IRTA shall have no obligation to review such Postings and assumes no responsibility or liability relating to any such Postings. Nonetheless, IRTA may from time to time monitor IRTA-sponsored Postings in its sole discretion and in accordance with law may remove and/or decline to publish any material, including but not limited to: (i) any Postings that contain any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, profane, hateful, racially, ethnically or otherwise objectionable material of any kind (ii) advertisements or solicitations of any kind; (iii) messages posted by visitors impersonating others; (iv) Personal Information, such as messages which list phone numbers, personal identification numbers, account numbers, addresses, or employer references; (v) messages by unrelated third parties purporting to speak on behalf of the IRTA; (vi) multiple messages by the same visitor restating the same point; (vii) messages of commercial or reputational damage to IRTA; and (viii) chain letters of any kind.
Member Communications and Membership Applications. Contacts by IRTA with its members by phone, text, mail or email, as applicable, shall be deemed private or confidential and any information contained therein shall be treated as Personal Information. IRTA may, in its sole discretion, record telephone conversations with members, as permitted by law. IRTA may also collect and use Personal Information provided in the processing of membership applications.
Location of Personal Information
IRTA is a global organization and collects and processes Personal Information from countries throughout the world. Therefore, subject to applicable laws, Personal Information may maintained and used in countries other than from where Personal Information was collected or where IRTA is physically located. Data protection laws vary from country to country. Regardless of the county from where Personal Information is collected, processed, or used, the Personal Information will be protected in accordance with this Policy.
Third Party Access to Information
Personal Information shared with companies or individuals working on IRTA’s behalf will be protected by requiring those parties to enter into non-disclosure agreements with IRTA to safeguard the confidentiality of such Personal Information.
Retention of Personal Information
IRTA retains Personal Information for such duration as it determines is appropriate and in accordance with its records and information management policies. IRTA will then take reasonable measures to ensure that all Personal Information is deleted or destroyed in its entirety.