Last Revised: June 1, 2018
This Privacy Policy explains how Association for Corporate Growth, Inc. (“ACG”) may collect, use, share, and safeguard information that you provide to us, or that we collect when you use www.acg.org, mobile websites, microsites, mobile applications, profiles on ACG social media sites and any other digital services and platforms officially operated or used by ACG from time to time (the “Sites” or “Services”). In certain Sites operated overseas, the Privacy Policy displayed on those Sites, not this Privacy Policy, will govern the collection, use, and sharing of information.
Changes to the Privacy Policy
As ACG, changes its membership and benefits change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the “Last Revised” date at the top and bottom of this document.
1. Collection of Personal Information
A. Information You Directly and Voluntarily Provide to Us.
Membership: If you provide your Personal Data to ACG to become a member of ACG, or if you sign up to become a registered user of any website operated by ACG, you will be required to provide certain information as part of the registration process. This information will include your first and last name, organization, title, email address, phone, industry, professional classification, number of employees and business or home address. We may also request that you voluntarily provide other information, such as your phone number, date of birth, demographic information, educational background and professional experience. Membership information is used to communicate with you, to design content and activities that we believe would be of interest to you, and to ensure that ACG will not violate any applicable U.S. sanctions in providing you access to ACG’s goods and services. If you wish to opt-out of receiving these communications from us, please follow the instructions contained in an applicable communication you receive from us or email privacy@acg.org and submit a request.
Events and Conferences: ACG may host events that include in-person, knowledge sharing and webinars. If you register for an ACG event and you are an ACG member, we will access the information in your member profile to provide you with information and services associated with the event. If you register for one of our events and you are not an ACG member, we will collect your first and last name, email address, business or home address, phone number, title, professional classification, and responses to conference related questions such as dietary restrictions, and the type of business you work for or with, which we will use to provide you with information and services associated with the event.
Publications: We offer various publications and materials through our Sites. Some of these publications and materials are publicly accessible, however, others require that you to be an ACG member, or that you create an account and subscribe to receive these publications and materials. If you are not an ACG member and you create an account for this purpose, you will be required to provide certain information as part of your account registration, including your first and last name, email address, and business or home address and professional information. You may manage your ACG subscriptions by subscribing or unsubscribing at any time. If you have any difficulties managing your subscription or other preferences, email privacy@acg.org.
Communications with ACG: If you communicate or correspond with us by email, through postal mail, via phone or through other forms of communication, we may collect the information you provide as part of those communications. For example, if you correspond with us through email or website forms, we may collect and store the email address you use to send the applicable correspondence and use it to respond to your inquiry; to notify you of ACG conferences, publications, or other services; or to keep a record of your complaint, accommodation request, and similar purposes.
B. Information We Automatically Collect from You.
We may automatically collect information about you when you use the Sites or our services. For example, if you access the Sites through a computer, we will automatically collect information such as your browser type and version, computer and connection information, IP address and standard web log information. If you access the Sites through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer. This information that we automatically collect from you is used to enhance the performance of ACG’s website. ACG also uses your location information (if shared with ACG) to identify the geographic locations from which our content is accessed so that we can better understand what content topics may be most relevant in that region, and to ACG members generally, and to develop resources around those content topics.
We may automatically collect information from you when you use the Sites using “cookies” and other similar technologies, such as web beacons. Cookies are small amounts of data that are stored within your computer’s Internet browser and that are accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online at a later time. The cookies are not able to execute code or access other information stored on the computer. Web beacons are transparent pixel images that are used in collecting information about website usage, email response and tracking.
Information that may be collected by cookies when you use the Sites may include, without limitation:
- the pages you visit within the Sites;
- the date and time of your visit to the Sites;
- the amount of time you spend using the Sites;
- the Internet Protocol (IP) address used to connect your computer to the Internet; and/or
- your computer and connection information such as your browser type and version, operating system and platform.
This information is collected to enhance the site performance and end user experience. You can set your browser to reject cookies or to notify you when you are sent a cookie. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser. In addition, to find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
ACG will not associate identifiers from cookies or similar technologies with sensitive identifiers about you, such as race, religion, sexual orientation or health.
C. Information Collected by Third Parties through Third-Party Links and Content.
The Sites may include links to other websites and other content from third-party businesses and can offer direct interaction with external websites, networks or platforms that are outside ACG’s control. These third-party businesses may use cookies, web beacons or other similar technology to collect information about you. ACG does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the security, privacy of the information collected by these third parties or the privacy practices of these third parties or the content on any third-party website. You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on our Sites (see Section 3 below for additional information about Online Advertising).
D. Information Collected by Third-Party Analytics Services.
We may work with third-party analytics services to help us understand how the Sites are being used, such as tracking the frequency and duration of use of the Sites. We may use Google Analytics, and web analytics services provided by Google (“Analytics Tools”) to collect information about your use of the Sites. Google Analytics Tools may use cookies to collect information about the content you view, what websites you visit immediately prior to and after visiting the Sites, and your system information and geographic information. The information generated by these cookies about your use of the Sites will be transmitted to and stored by Google Analytics. The information collected by Google Analytics allows us to analyze your use of the Sites. The Google Analytics may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the Sites. At the moment that you cancel your ACG membership or withdraw your consent for the processing of personal information, ACG will not be able to access the personal information processed by third-party analytics. By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can opt-out of Google Analytics by installing Google’s opt-out browser add-on, and out of interest-based Google ads using Google’s Ads Settings.
E. Information You Share on Third-Party Websites or through Social Media Services.
The Sites may include links to third-party websites and social media services where you will be able to post comments, stories, reviews or other information outside of ACG’s control. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. ACG is not responsible for the security or privacy of any information collected by other websites or other services. Information collected by third parties is governed by their privacy practices. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services.
F. Information You Share on the Sites.
If you decide to share your information in the members’ only membership directory on www.acg.org, that information may be collected and used by ACG and other users of the Site. The membership directory may include the following personal data: name, company, business or home address, email, phone, website, social media handles, chapter, bio, education, professional experience and demographics. In addition, if you are an ACG member or non-member event registrant user and choose to be included on the event attendee list or participate in event networking apps, which are provided by our third-party vendors, postings you make in connection with those features will be associated with the personal information in your public member profile (which includes your name, and other optional information you may choose to include). ACG may share the following personal data with third-party vendors platform and other ACG platforms: name, company, business or home address, email, phone, website, social media handles, chapter, bio, education, professional experience and demographics. We strongly recommend that you do not post any information on the public areas of the Sites that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
G. Information You Provide to Payment Processors.
All payments made to ACG are processed by a PCI/DSS-compliant (these are payment card industry security standards) payment processing service engaged by ACG. All information collected by these third-party providers for purposes of processing your payments is not available to us, unless you have otherwise provided this information to us in connection with your use of the Sites or our products and services.
H. Personal Information Provided by Third Parties.
We may receive personal information about individuals from third parties. This may happen if your employer pays and registers you for membership or events however, we will only share information about you with your employer if you consent in advance to our sharing this information. Our third-party registration partners may also share your personal information with ACG when you register for an event.
2. Online Advertising; Tracking
ACG and third-party businesses may use the information collected through the Sites using cookies, web beacons, and other similar technologies to help manage online advertising programs. This information may enable ACG and our third-party advertising services and other third-party businesses to track the actions of users online over time and across different websites or platforms to measure statistics relating to marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the consumer experience. For information about how tracking works for online advertising purposes, and what happens when you elect a do-not-track option, visit http://www.aboutads.info/choices. In addition, some third-party businesses may provide a mechanism to opt-out of their technology. For more information about the opt-out process, you may visit the Network Advertising Initiative website, available at: http://www.networkadvertising.org/managing/opt_out.asp.
3. Use, Sharing and Retention of Personal Information
A. How We Use Your Information.
ACG uses personal information for the purposes described at the time of collection, to provide membership benefits and other services to you, including processing of membership applications, or registering you for event or webinar programs and to otherwise process your requests or address your inquiries. ACG also uses your information, as permitted by law, to provide you with information about ACG and services or other products and services in which we believe you may be interested. If you are a member or registered user, we may email you about products and services that we believe may be of interest to you. If you wish to opt-out of receiving these emails from us, please follow the instructions contained in an applicable email you receive from us, which will allow you to opt-out of receiving these types of email communications from us. We may also use your personal information to help us understand our members’ needs and interests, to better tailor our products and services to meet your needs.
B. How We Share Your Information with Third Parties.
Except as set forth in this Privacy Policy or when specifically agreed to by you, we will not disclose personal information we gather from you to third parties unless ACG is required to share this information to complete your request or for legitimate business purposes. ACG shares personal information in the following circumstances:
Third-Party Service Providers. We may share your information with vendors or third parties who deliver or provide goods and services or otherwise act on behalf of or at the direction of ACG. These third parties may include, for example, our third-party technology providers, including our database vendors, website developers, event registration vendors, mail houses for print materials, and third-party event hosts, hotels for conference registrants, sponsors, co-sponsors and exhibitors. These third-party service providers will only have access to the information needed to perform these limited functions on our behalf. If you do not wish to have your information included in an attendee list or to receive information from sponsors, co-sponsors and/or exhibitors, you can express your preferences when you register for events or you may contact ACG directly at privacy@acg.org.
Volunteers and Board Members. We may share your information with our affiliates, subsidiaries and ACG volunteers and board members for purposes of conducting ACG’s internal business operations. ACG also makes publicly available the names, titles, country and business affiliations of officers, committee members and others who have assisted with initiatives or projects.
Other ACG Organizations. We may share your information with your local ACG chapter so that they may offer membership and associated services to you pursuant to your membership in that Chapter, as well as other ACG chapters to provide information regarding their programs and initiatives.
ACG Events. If you are an event attendee, speaker, or sponsor, certain items of your information may be included in the event roster, which will be publicly disclosed, and may also be shared with third-party event sponsors and exhibitors. Your information may also be shared with the conference application vendor. ACG provides conference attendee information to conference application vendors (First Name, Last Name, Company Name, Country, Work phone, Preferred Address, Fax, Username and Email address. Pitchbook administers the conference mobile application and validates that you are an attendee before this application can be downloaded by you. Any data Pitchbook collects is deleted by Pitchbook after the event takes place. Further, by registering and attending an ACG event, you agree irrevocably, with no compensation to you, that ACG or any third party who is acting on ACG’s behalf may create images, videos and/or sound recordings of you (“works”) at the event for marketing purposes. This grant of rights in the works also includes the rights to adapt, reproduce, distribute, perform, make available to the public, broadcast, retransmit or sublicense the works to ACG’s affiliates. This grant of rights in the works also includes all current and future media and is not restricted to time or territory.
Response to Subpoenas, Court Orders, Government Requests or to Protect Rights and to Comply with Our Policies. To the extent permitted by law, we will disclose your information to government authorities or third parties if: (a) required to do so by law or regulation, or in response to a subpoena or court order or any other enforceable governmental request or order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (c) we believe that you have abused the Sites by using them to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
Aggregate Information. We may share your information with affiliated or unaffiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally. Where we do share your personal data with third parties, ACG takes steps to ensure that they use appropriate safeguards to protect your personal data.
C. Information for Individuals Located in the European Union.
Legal Basis for The Processing of Personal Information from EEA Residents
If you reside within the European Economic Area (EEA), our processing of your personal information will be legitimized as follows:
(i) Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.
(ii) If the processing of your personal data is necessary for the performance of a contract between you and ACG or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). If this data is not processed, ACG will not be able to execute the contract with you.
(iii) Where the processing is necessary for us to comply with a legal obligation, we will process your information on basis of GDPR Article 6(1) lit. (c), for example complying in the fields of employment law.
(iv) And where the processing is necessary for the purposes of ACG’s legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to detect fraud.
Transferring Personal Data from the EU to the US:
ACG has its headquarters in the United States. Information we collect from you may be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR). A finding of “adequacy” in short means that the European Commission has decided that this country outside the EEA ensures an adequate level of data protection. ACG relies on derogations as set forth in Article 49 of the GDPR as the United States has no “adequacy” decision and no other safeguards under the GDPR are in place (for example binding corporate rules on the transfer outside the EEA). In particular, ACG collects and transfers to the U.S. personal data only: with your explicit consent; to perform a contract with you; in a manner that does not outweigh your rights and freedoms. If this data is not processed and transferred, ACG will not be able to execute the contract with you or you will not have access to any or all of the benefits and features associated with your transaction. ACG endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with ACG and the practices described in this Privacy Policy. ACG also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.
If you wish to confirm how ACG is processing your personal data, or to have access to the personal data ACG may have about you, please contact us at privacy@acg.org.
European Union Data Subject Rights
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects (these are persons that can be identified).
This Privacy Policy is intended to provide you with information about what personal data ACG collects about you and how it is used.
If you wish to confirm that ACG is processing your personal data, or to have access to the personal data ACG may have about you, or have other questions, please contact us at privacy@acg.org.
You may request information via privacy@acg.org about: the purpose of the processing; the categories of personal data concerned; who else outside ACG might have received the data from ACG; what the source of the information was (if you did not provide it directly to ACG); where the personal data is stored and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by ACG if it is inaccurate. You may request that ACG erase that data or cease processing it, subject to certain exceptions. You may also ask ACG for your personal data to be supplemented or updated, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. You may withdraw your consent for the processing of personal data or the further processing of personal data by ACG at any time. You may also request that ACG cease using your data for direct marketing purposes. In many countries (including EEA countries), you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how ACG processes your personal data. When technically feasible, ACG will—at your request—provide your personal data to you or transmit it directly to another controller. You have the right to receive your personal information in a structured and standard format.
In addition to the information contained in this Privacy Policy, you may be provided with additional and contextual information concerning particular services or the collection and processing of your personal data upon request.
Reasonable access to your personal data will be provided at no cost to ACG members, conference attendees and others upon request made to ACG at via privacy@acg.org. If access cannot be provided within a reasonable time frame, ACG will provide you with a date when the information will be provided. If for some reason access is denied, ACG will provide an explanation as to why access has been denied.
D. Security of Your Information.
ACG uses reasonable physical, technical and administrative measures to safeguard personal information you provide through the Sites or in connection with ACG’s products and services. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, ACG cannot guarantee or warrant the security of any information you transmit on or through the Sites and you do so at your own risk.
E. Data Storage and Retention.
Your personal data is stored by ACG on its servers, and on the servers of the database management services ACG engages, located in the United States and other countries. ACG retains data for the duration of the customer’s or member’s business relationship with ACG and otherwise as required under applicable law. Personal data will be kept for no longer than is necessary for the purposes for which your personal data are processed. We will retain your personal data as long as you are an ACG member or require our services so that we can provide these services to you.
If you are located in the European Economic Area, at the moment you cancel your ACG membership or withdraw your consent for the processing of your personal information, all your personal data received and stored are erased if no longer needed by us. Unless we are required to retain this personal data by law or to comply with our regulatory obligations. In such a case, we will only keep this personal data for as long as necessary. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact our data privacy resource at privacy@acg.org.
4. Special Information for California Residents.
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us through our contact form or email at privacy@acg.org.
5. How to Contact ACG and Modify Your Information or Preferences.
Questions regarding this Privacy Policy should be directed to ACG’s data privacy resource: privacy@acg.org. If you would like to modify the types of marketing email messages you receive from ACG, you may do so by following the instructions within the body of any email message that you receive from us.
To help us keep your personal information up to date, or to request access to the personal information ACG maintains about you, you may contact us at privacy@acg.org. Or, if you are a registered user of one of our Sites, you may go online to your personal profile and update your information in that area.
6. Children.
ACG is a professional membership association and the Sites are not directed to children under the age of 13. ACG does not knowingly collect personally identifiable data from persons under the age of 13 of COPPA (The Children’s Online Privacy Protection Act). If you are a parent of a child under 13, and you believe that your child has provided us with information about him or herself, please contact us at privacy@acg.org.
7. Questions, Concerns or Complaints
If you have any questions or concerns about this Privacy Policy, please contact ACG’s data protection resource at: privacy@acg.org.
Last Revised: June 1, 2018