Effective as of March 2019

 

COLA (“we”, “us,” or “COLA”) has developed this policy statement to assist end users (“you” or “user”) of the COLA family of sites in understanding why COLA (or one of its affiliates) collects particular personally identifiable information (the “Privacy Policy”).  The following Privacy Policy summarizes the personally identifiable information gathering and use practices for any of the United States Web sites owned and operated by COLA (collectively, the “Site”).  Personally identifiable information (“PII”) includes information that can be linked to a specific individual, such as a name, address, phone number, or e-mail address.

 

COLA reserves the right to change this Privacy Policy at any time.  If COLA makes changes to this Privacy Policy, COLA will post those changes at this location and provide notice of any material changes so that you are more aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.  Please review this Privacy Policy on a periodic basis.

 

What Information Does COLA Collect?

 

PLEASE NOTE: THE TYPE OF DATA COLLECTED BY COLA WILL VARY WITH YOUR USE OF THE SITE AND CERTAIN DATA SUBMISSION IS VOLUNTARY.  Below, we provide specific examples of the types of PII COLA may collect through the Site.

 

Contact Information:  COLA may request or require contact information, such as your name, address, phone number, facsimile number, and e-mail address.

 

Demographic Information:  COLA may collect demographic and general profile data (e.g., educational, professional, accounting, and geographic information).

 

Transactional Information:  COLA may maintain a database of aggregated information about the transactions on the Site (e.g., tool or feature (and related database) utilization, registration information, and article, conference, activity, or content selection data).

 

Financial Information:  COLA may use credit card account information.

 

Technical Information:  COLA may also collect Internet Protocol (IP) addresses from all users of our Site as well as the date and time of access and the Web page(s) accessed.  COLA may also catalog your log-in information and the type of computer, browser, or operating system used by the user.

 

How Does COLA Use that Information?

 

To operate the Site and provide certain of its features, tools, and functionality (including any online application or solution) and otherwise improve the quality of the information and services COLA offers to you, COLA collects various PII (as described above) from different parts of its Site.  COLA gathers most information during the registration processes it utilizes to allow for and to enable use of the Site and its online tools and certain other solutions, information, directories, seminars, and/or services.  But, COLA may request PII at other times, including, but not limited to, when you report a problem with the Site, when you complete survey forms, when you sign up for program or event opportunities through the Site, and when you request to receive communications from COLA.

 

The Site offers two different levels of access and service: (1) publicly available information areas and (2) registered user areas where an individual can access particular features, applications, courses, and tools (the “Registered User Section(s)”).  Parts of the Site are informational in nature and publicly available to all users.  Consequently, until you register, participate in surveys, sign up for a program or event, or receive information from COLA, you are able to browse areas of the Site without providing any PII, although your browser may tell us what type of computer and operating system you are using as well as other kinds of technical information.

 

Below, is more detail on how COLA uses your PII.

 

Contact Information:  COLA may use your contact information in connection with the provision of its solutions, services, and content, including such services or online software applications related to or enabling storage of your PII, and to enable you to participate in the Site’s activities, applications, and offerings.  COLA may also use your contact information to facilitate registration with a particular program or event, to advertise its services and the goods and services of third parties, to create a personalized experience for you, to provide you with news and information, to contact you regarding a survey, and to get in touch with you when necessary with respect to transactions conducted through the Site, material changes in our Site’s policies and agreements, new services COLA may offer, or otherwise.  In addition, we may supplement the PII collected from you with information from other sources, such as from our affiliates or business partners, or engage in cross-border transfers of PII in order to provide or enhance our ability to provide or advertise our services and/or the services of others and to otherwise tailor the Site.  Please also note that certain PII will be made available for public review on the Site in connection with the Site’s directory feature.  We also share your contact information with our agents, contractors, and business partners, as is necessary to provide or improve our services or online solutions, including any services for storage of PII or support of systems processing or storing PII, and to allow for the on-line registration for events, the online provision of software applications, the on-line submission of donations, for advertising purposes, for market analysis, and for internal business purposes.

 

Demographic Information:  COLA may use demographic information in connection with the provision of its online software applications or for administrative, management, and monitoring purposes in order to continue to provide or improve the Site and its solution and service offerings.  In addition, COLA may share, license, and/or sell survey results and aggregated demographic data collected through the Site with its affiliates, business partners, the general public, the news media, and with the U.S. Government and state governments, not only as may be required by law, but also for advertising purposes, for release to third parties, and to participate in government programs and initiatives.  But, such survey or aggregated information will not identify any particular user.

 

Transactional Information:  COLA may share, license, and/or sell transactional data on an aggregated basis, which will not identify any particular user, with advertisers or other third parties, including our business partners, for business purposes.

 

Financial Information.  COLA may use credit card information to process payments for products, programs, or services on the Site, including online software applications requiring a fee.

 

Technical Information:  COLA may use technical information, such as your IP address or browser type, to help diagnose problems with our servers, analyze Site usage trends, track user movements on the Site, and to otherwise manage and monitor our Site.

 

Business Transactions:  In the event that COLA goes through a business transaction, such as a merger or acquisition by another entity involving the sale of all or a portion of its assets, please note that the PII collected and retained by COLA may be among the assets transferred.  In the event a transaction of this kind occurs that results in the transfer of PII, COLA will notify you via e-mail and/or place a prominent notice on the Site for thirty (30) days of any such change in ownership or control and the possible changes to this Privacy Policy.

 

Legal Action.  COLA may disclose PII when legally required to do so in accordance with government requests or regulations or legal proceedings.  We may also disclose PII to protect against misuse or unauthorized use of the Site or as is otherwise required to limit legal liability, protect or defend our rights, property, or interests, or protect the safety, rights, or property of our users.

 

What About the Use of Cookies and Other Automated Data Collection Techniques?

COLA may use cookies and/or other similar programming techniques to enhance and/or monitor your experience while using our Site.  Cookies and other related techniques are generally pieces of information, which COLA uses for record-keeping purposes, which the Site transfers to us and/or your computer’s Web-browser for storage on your computer’s hard drive.  Cookies and other related techniques enable COLA to manage and/or customize your experience on the Site.  Cookies and other related techniques also make Web-surfing easier by automatically performing certain functions such as saving your personal preferences and by ensuring that you don’t see the same advertisement repeatedly.  COLA, however, will not use cookies to record passwords or credit card or other financial information.  Moreover, you can delete any cookies residing on your hard drive by following the instructions for your Web browser.

 

Many consider the use of cookies to be an industry standard.  Consequently, your Web browser is likely set to accept cookies.  If you would prefer not to receive cookies, however, you can alter the configuration of your browser to refuse cookies.  If you choose to have your browser refuse cookies, you should understand that it is possible that some areas of our Site will not function properly when you view them.

 

What About External or Third Party Web Sites?

To the extent hyperlinks or gateways (whether through banner advertisements or otherwise) are utilized to access external or third party sites, you should be aware that these external or third party sites may collect PII and are not controlled by COLA and therefore, are not subject to this Privacy Policy.  COLA suggests that you check the privacy policies of these sites to determine how the proprietors of these third party sites will utilize your PII.

 

What About Security?

As is appropriate for the nature of PII collected and stored by COLA, the Site has industry standard security measures or safeguards in place to protect against the loss, misuse, and alteration of the information under COLA’s control.  Although COLA has endeavored to create a secure and reliable Site, the confidentiality of any communication or material transmitted via the Internet cannot be guaranteed.  Accordingly, you should consider carefully if you want to submit sensitive information via the Internet.  COLA urges you to take every precaution to protect your PII when on-line.

 

What About “Opting-Out” of Data Collection and Use?

The collection, use, and distribution of your PII is necessary for COLA to provide certain features, solutions, applications, and services and to operate the Site.  For example, all users who register for the Registered User Section(s), subscribe to online solutions or applications, purchase goods, register for an event, program, seminar, or training, and/or seek to receive information or newsletters from COLA will need to agree to COLA’s use and collection of PII.    Once registered with the Registered User Section(s), COLA maintains your information so long as you are registered as a user and/or for COLA’s services at the Site.

 

But, a number of COLA’s other programs are completely voluntary and as you are otherwise permitted to browse through and access the non-restricted areas of the Site, you can decide on your own if you wish to provide your PII or opt-out of doing so.  For example, if COLA conducts a survey, you do not have to participate unless you agree to do so.

 

COLA also provides you with the opportunity to opt-out of certain COLA business practices where your PII may be used.  Specifically, users my opt-out of including the PII they provide to COLA in connection with the following activities: (i) inclusion in user mailings, (ii) e-mail communications sent by COLA, (iii) facsimile communications sent by COLA, (iv) particular advertisements, and (v) certain sharing arrangements with COLA’s business partners.

 

Thus, to a large extent, you can control the information you provide or share with COLA and/or its business partners.  Moreover, even when COLA contacts you, from time to time, regarding its products/services, the Site, or otherwise, if COLA sends you such a communication, COLA specifically provides you with the opportunity to opt-out of receiving similar future correspondence or to revise the frequency of any future communications by sending an e-mail to info@cola.org.

 

What About Correcting, Deleting, or Updating Information?

At any time, you may go to the Site and your personal account (using your username and password) to correct, modify, or delete the information you provide to COLA through the Site, namely, your name, email address, phone number, or address.  In addition to the ability to make direct changes to the information stored in connection with your user/user profile, you may also e-mail info@cola.org with any requests or changes.  Moreover, when you cease to use COLA’s services or no longer wish to be included in COLA database, you may contact COLA at info@cola.org to request to have your information removed from our database.  In the event that COLA receives such a request or change, COLA may require you to confirm or verify any change to your record.  Please note, however, that the collection and uses of certain PII is necessary to provide certain products and services through the Site and the deletion of such necessary information, e.g., an e-mail address, may render a particular service or COLA’s ability to provide it inoperable.

 

What About Children?

COLA cares about the safety of children on its Site and encourages parents and guardians to monitor their children’s use of the Internet.  Although the Site is suitable for a general audience, the Site is intended for use only by users who are over 18 years of age.  Accordingly, COLA does not knowingly solicit PII from children or send them requests for personal information.

 

What About Governing Law?

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of Maryland, U.S.A.  The Site and the servers that host the Site are located in the United States.  Any information you provided will be transferred to the United States.  By visiting and using the Site and submitting PII thereto, you therefore authorize this transfer of your PII to the United States.  If any part of this Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision or part will be deemed suspended by a valid, enforceable provision that most closely matches the intent of the original provision or part and the remainder of this Privacy Policy shall continue in full force and effect.

 

What About Any Other Questions?

If you have any questions about this Privacy Policy, the information collection and dissemination practices of the Site, or COLA’s use of your PII, you can contact COLA at info@cola.org.