Privacy Policy of the Federation of Defense & Corporate Counsel and the FDCC Foundation

GENERAL DISCLOSURE

This Privacy Policy governs the collection, use and disclosure of personal information on www.thefederation.org (the “Website” or “Site”) and its associated mobile app, both of which are operated by the Federation of Defense & Corporate Counsel (“FDCC”) and the FDCC Foundation (collectively, “we” or “us”).  We define “personal information” as any information about an identifiable individual. This Policy outlines the type of information that the Website’s operators and their members, officers, management company and affiliates (collectively, “we” or “us”) gather about users of this Website (“you” or “your”) while using this Website and how we use and disclose that information.

Please read this Privacy Policy as, by using this Website, you agree that your use of this Website is governed by this Privacy Policy. We reserve the right to modify this Privacy Policy at any time. We will reflect any such modifications to this Privacy Policy on this Website. Your continued use of this Website after any such changes constitutes your acceptance of this Privacy Policy, as revised.

This Site is hosted in the United States. If you are visiting this Site from outside of the United States, please note that by providing your information it is being transferred to, stored or processed in the United States, where our data center and servers are located and operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country of residence. By using our Website, you understand that your information will be transferred to our data center and servers in the United States and to third parties with whom we may share your personal information. If you are visiting this Website from outside the United States and do not wish to allow the transfer of your personal information within the United States, you should not use this Website and opt-out of the use of cookies.

 

We take your privacy and the protection of your personal information seriously. We will only store, process, and disclose your personal information where we have your consent or a legitimate interest and in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.

 

Information Collection and Use

The Website and associated mobile app provide FDCC members and industry practitioners with relevant information, tools, and resources with which to advance their practice of law, connect, collaborate, and refer business to one another, pay membership dues, register for meetings and events, and donate to the non-profit FDCC Foundation (“Services”).

 

For a better experience while using our Services, we may require you to provide us with certain personally identifiable information, including but not limited to your name, phone number, email and postal address (“Personal Information”). The information that we collect may be used to contact or identify you.

This page is used to inform website visitors regarding our policies in regard to the collection, use, and disclosure of Personal Information if anyone decided to use the FDCC website and mobile app.

If you choose to use our Services, then you agree to the collection and use of information in relation with this policy. The Personal Information that we collect is used solely for internal purposes of the FDCC and FDCC Foundation, and for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

We also may collect information about your computer or mobile device and your visits to this Site, such as your IP address, geographical location, browser type, referral source, length of visit and number of page views. We may use this information in the administration of this Site, to improve the Site’s usability, to provide better service, to send you newsletters, legal updates, marketing communications, and other information that may be of interest to you. We may also use outside services such Google Analytics to gather data about our Site visitors. We may sometimes permit our authorized service providers to have access to aggregate statistics about our clients, Site traffic patterns, usage, and related information.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is defined in this Privacy Policy.

Log Data

Whenever you visit our website, or use our mobile app, we collect information that your browser sends to us that is called “Log Data”. This Log Data may include information such as your computer's Internet Protocol (“IP”) address, browser version, pages of our website and app that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

Cookies

Cookies are files with small amounts of data that is commonly used as an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer's hard drive.

Our website uses these “cookies” to collect information and to improve our Services, such as your identification so as to permit you to access member-only information and pages on the website. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Services.

Service Providers

We may employ third-party companies and individuals for the following reasons:

  • To facilitate our Services;
  • To provide the Services on our behalf;
  • To perform Service-related services; or
  • To assist us in analyzing how our Services are being used.

These third parties have access to your Personal Information, to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

Security

We value your trust in providing us your Personal Information. We are fully PCI compliant and, therefore, ensure that commercially acceptable measures remain in place to protect your Personal Information. You are reminded that no method of transmission over the internet, or method of electronic storage is 100 percent secure and reliable, and we cannot guarantee its absolute security.

Links to Other Sites

Our Website contains links to other sites. If you click on a third-party link, you will be directed to that site. We are not responsible for the privacy practices or the content of such other websites, including any sites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). We do not share information we gather with other websites or any other entities or individuals unless such sharing is approved in advance by you. Other linked websites, however, may collect personal information from you that is not subject to our control. To ensure the protection of your privacy, always review the privacy policy of the websites you may visit by linking from the Site. Please note that this Privacy Policy applies only to this Website and not to other companies’ or organizations’ websites to which we link.

For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you’ve provided to them or they’ve collected from your use of their services. This information will be stored in Google’s servers in the United States of America according to their privacy practices and policies.

CHILDREN’S PRIVACY

The U.S. federal Children’s Online Privacy and Protection Act (“COPPA”) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personally identifiable data relating to any person under the age of 18. If you are under the age of 18, please do not supply any personally identifiable data through the Site. If you are under the age of 18 and have already provided personally identifiable data through the Site, please have your parent or guardian contact us immediately at bernie@thefederation.org so we can remove such information from our files.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with us, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Site users, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process, or other law enforcement measures. We may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services.

RETENTION OF PERSONAL INFORMATION

We may keep a record of your personal information, including correspondence or comments, in the applicable file specific to you. We will utilize, disclose, or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal compliance and data retention policies.

YOUR CHOICES AND ACCESS TO YOUR PERSONAL INFORMATION

Where applicable law provides, and subject to the exceptions and limitations provided by that law, we will make available to you any specific personal information about you that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. Simply send your request for access, by sending an e-mail to bernie@thefederation.org. We may ask for additional information to determine the law applicable to your request.

If you no longer wish to receive marketing communications from us, you can let us know by sending an email to bernie@thefederation.org. Each of our marketing emails also contains an unsubscribe link so that you may unsubscribe from the applicable list or lists.

If you are located in either the European Union (“EU”) or the European Economic Area (“EEA”), the General Data Protection Rule (GDPR) allows Data Subject rights of access, rectification, erasure, restriction, objection or portability in line with the type of services being provided and the right to lodge a complaint to your Supervisory Authority.

YOUR RIGHTS IF YOU ARE A CALIFORNIA RESIDENT

If you are a California consumer, the California Consumer Privacy Act (“CCPA”) gives you certain rights with regard to specified information that identifies you or your household (“Personal Information”). This Privacy Notice is provided so that you can understand at or before the point of collection what we are collecting and why. Please note that until January 1, 2021, the rights described in the CCPA to know, to delete, and to data portability do not apply to you in your capacity as a job applicant, employee, or business-to-business contact.

Information We Collect. Personal Information may be collected directly from you, from third parties, or automatically when our services are used. Below is a description of the categories of Personal Information we collect and the sources from which the Personal Information was collected.

Job Applicants. If you apply for a job with us, various information may be collected through applications and various employment forms, HRIS, third party vendors (background screenings and insurance providers, retirement plan bank/custodians, etc.), benefit election forms, beneficiary forms, etc. Such information may include the following: names, addresses, phone numbers, social security numbers, copies of governmental ID, date of birth, pay/benefit deduction data, personal banking information, dependent and beneficiary personal data including social security numbers, emergency contact information, tax withholding info, court ordered wage attachment, qualified domestic relations orders, medical/family/personal leave of absence data, marriage and death certificates, and other information that you voluntarily provide or that government agencies provide about you or on your behalf.

Marketing. We may obtain the following information automatically from you upon subscribing to the Website, to send you communications for marketing purposes that are relevant to you: name, title, company, department, addresses, phone numbers, email addresses, assistants' names and phone number, and company website address.

Payment. We may obtain the following information from vendors or client/matter files to obtain payment or to pay vendors: vendor files, client files, matter files, names, addresses, email addresses, tax identifications, banking information, credit card numbers.

Events. We may obtain the following information collected upon your registration for an event sponsored by us: name, address, phone number, title, company, and email address. The particulars of the data collected in connection with events will be reflected in the registration forms you fill out.

Your Rights with Regard to Your Personal Information. As a California consumer, you have the following rights, in certain circumstances, in relation to your Personal Information:

  1. The right to understand the collection and use of your Personal Information.
  2. The right to request that Personal Information be erased.
  3. The right to obtain a copy of your data in a reasonably useful electronic form (in certain specific circumstances).
  4. The right to opt-out of the sale of your Personal Information.

A summary of each right and how an individual can take steps to exercise it is set out below. See Contact below for information on how to contact us regarding exercising these rights.

Right to Understand the Collection and Use of your Personal Information (“Right to Know”). Subject to any applicable legal limitations, you have the right to request, and receive information on:

  1. The categories of Personal Information we have collected about you.
  2. The categories of sources from which the Personal Information is collected.
  3. The business or commercial purpose for collecting or selling Personal Information (if applicable).
  4. The categories of third parties with whom we share Personal Information.
  5. The specific pieces of Personal Information we have collected about you.

Right to Request the Deletion of Your Personal Information (“Right to Delete”). You may request that we delete your Personal Information. We will do so, except in the following circumstances:

  1. Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3. Debug to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

These rights do not extend to anonymized or aggregated information that can no longer be connected to you personally.

Your Right to Access and Data Portability (“Right to Data Portability”). Subject to any legal limitations on our ability to do so, where we receive a verifiable request from you, you are entitled to a copy of the Personal Information that we have collected on you that, to the extent technically feasible, would allow you to transmit that data to another entity without undue hindrance. In addition, we may provide Personal Information to you at any time, but we are not required to provide Personal Information to you more than twice in a 12-month period.

Right to Opt-Out of the Sale of your Personal Information. We do not sell the Personal Information of California customers and has not done so in the past twelve (12) months.

Rights of Minors. Our website is not directed to persons under the age of 13, and we do not knowingly store personal information of any kind relating to such persons. If you are the parent or guardian of a minor and believe that minor’s personal information has been collected, please contact us so that we may delete it.

Right to Not Receive Discriminatory Treatment. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

Financial Incentives. We do not offer financial incentives to consumers based upon the retention of a consumer’s personal information.

Exercising your rights. If you wish to exercise any of your rights under the CCPA, please contact us using one of these methods:

  1. Email: bernie@thefederation.org
  2. Phone:  (610) 992-0001

We may require that you provide sufficient information to verify your identity before we provide information about the existence, use, or disclosure of your personal information in our possession, as well as your requests under the CCPA and our responses. Any personal information collected in this process shall be used only for the purposes described above.

Your rights may be exercised free of charge, except where requests are manifestly unfounded or excessive, in particular, if they are of an abusive or repetitive character. Under such circumstances, we may charge a reasonable fee (which we will specify in advance) or may refuse to act on the request.

We will make every reasonable effort to respond to any of your written requests within the periods stated by California law, and if the law states no applicable period, within a reasonable amount of time.

We expect to provide access without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction, or transmission of such information. We will notify you, following your request for transcription, reproduction, or transmission, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

Contact Us

If you have any questions, concerns, or suggestions about our Privacy Policy, you may contact us at 610-992-0001, or via email at: bernie@thefederation.org.