Last Revised Date: March 17, 2020
We will strive to process your personal data lawfully, fairly, and in a transparent manner that complies with the General Data Protection Regulation (“GDPR”) as specified by the European Union. Your personal data will be collected for specified, explicit and legitimate purposes that align with the Services you have willfully engaged with or requested and will not be further processed in a manner that is incompatible with or needed to provide the requested Services. Our processing of your data shall be limited to that which is adequate, relevant, and limited to only what is necessary to provide you the requested services. Once we have processed or stored your data we will use reasonable efforts to assure your personal data is accurate, up to date, and eliminate inaccuracies we find or you notify us exist. We do not, however, assert, claim, or ensure the personal data you provide or is provided by others to us is accurate. We will use industry standard practices as to data retention and only retain as required by law. We will store data no longer than is necessary to provide you with requested services, or personal data may be stored for longer periods insofar as the personal data will be required for financial or legal reasons, or remains part of our normal archiving process when such data shall remain offline and not available to the public, or processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with GDPR Article 89(1). We implement industry standard practices to provide security and protect the confidentiality of your personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage. We periodically update our standard practices which can be obtained upon request.
We will process your personal data when you provide consent in compliance with all State and Federal laws, when the processing is necessary to provide you the service you requested, to protect your vital interests or that of someone else, when necessary to accomplish a task in the public interest, and when necessary for us to perform standard business and technical processes where such processes do not override your rights or that of a minor. If we must process or store your personal information for any other reason we will notify you and request your consent if such consent is required.
3. INFORMATION THAT IBA COLLECTS
During our normal course of business we do not collect, process, or store personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data for the purpose of uniquely identifying a natural person, health data, or data concerning a natural person’s sex life or sexual orientation. Should such personal data come into our possession or be processed by us from other sources, including you providing such data, we will erase this type of data upon your request or maintain such data upon your request with explicit consent by you. Only with your consent or for compelling reasons enumerated in GDPR Chapter 2 Article 2(2) or as compelled by law will we collect, store, or process such data.
You understand and acknowledge that providing personal data may be a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as obliged to provide personal data to access the site, services, or software and may be denied as the result of a failure to provide such data.
IBA collects two (2) types of information by and through the Websites and the Services: Personal Information and Non-Personal Information.
A. Personal Information. Personal Information is information that tells IBA specifics about you. The types of Personal Information that IBA may collect include, without limitation: your name and contact information (such as your postal address, zip/postal code, phone number and e-mail address); your password; and, in some cases, information on any entity or organization you below to, including government and academic institutions.
IBA may collect Personal Information from (and about) you in a variety of different ways. For example, when you register for a Service, such as membership, you submit Personal Information to IBA. Similarly, when you use the Websites or the Services to create or update a profile, register for events, or communicate or interact with IBA and/or its representatives, you are providing IBA with Personal Information. IBA may also acquire Personal Information about you from publicly available sources, social media platforms (e.g., Facebook) and other third parties that may share information as permitted in their privacy policies.
B. Non-Personal Information. Non-Personal Information refers to data and information that does not personally identify you as the individual to whom the data or information relates. Non-Personal Information may include, without limitation:
- The IP address assigned to your computer (or other device);
- Your media access control (MAC) address;
- Information derived through Collection Technology (see Section 5.A, below);
- The type of computer (or other device) you use, and the operating system you use (g., Microsoft Windows or Mac OS);
- The type of Internet browser you use (g., Microsoft Edge, Google Chrome, Mozilla Firefox or Safari);
- The domain name of your Internet Service Provider;
- Your activities while visiting or using the Websites or the Services (including the content you access or view, the time of your visit to or use of the Websites or the Services, and the pages you visit and the time spent on such pages);
- Your general geographic location (such as the city from which your computer or device is connecting to the Internet); and
- Information regarding the websites you visit prior to and after visiting the Websites or using the Services.
IBA may choose to receive and record Non-Personal Information on its server logs from your browser, as well as through other analytics in relation to the Websites and the Services. IBA may also obtain Non-Personal Information about you ‑ either directly or through inference ‑ from social media platforms, third parties and other lawful sources.
C. Information Obtained from Another Source. IBA will notify you within one month after obtaining information about you from another source, which may be a source offering publicly available information or a private source which you have given us permission to access. If we communicate with you using information we obtained from a third-party we will notify you at the time of communication that we have obtained such information.
D. Right to Erasure of Data. You have the right to obtain from us the erasure of personal data concerning you without undue delay and we will have the obligation to erase personal data without undue delay when: (i) your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (ii) you withdraw your consent on which the processing is based providing there is no other legal ground for the processing or retaining of your personal data; (iii) you object to the processing and there are no overriding legal or legitimate grounds for the processing; (iv) we have inadvertently or unlawfully captured or processed your personal data; (v) your personal data must be erased in order to comply with a legal order issued by a court of proper jurisdiction or to comply with a statute to which we are subject; (vi) your personal data has been collected in relation to the offer of information society services referred to in GDPR Article 8(1). Where we have made your personal data public and are obligated to erase the personal data, we will, after taking account of available technology and the cost of implementation, take reasonable steps, including technical measures at our disposal, inform others which are processing or storing your personal data that you have requested the erasure by such others of any links to, or copy or replication of, your personal data. You acknowledge that such public information may never be completely erased despite our efforts. We may not be able to erase your information, specifically when continued processing or storage is necessary for: (i) exercising the right of freedom of expression and information; (ii) compliance with a legal obligation which requires processing or storage where such legal obligation stems from a legal order issued by a court of proper jurisdiction or compliance with a statute to which we are subject; (iii) reasons of public interest in the area of public health as specified in the GDPR; (iv) archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with those specified in the GDPR; (v) or to assert, exercise, or defend legal claims.
4. USE AND DISCLOSURE OF INFORMATION
We will process and store your personal data while you continue to use the requested services and, upon termination of your use of the requested services, we will erase your personal data from active repositories and, through the normal course of business and technical processes, erase your personal information from archives and backup storage. We will employ industry standard practices as to removal from archive and backup storage which may impact the length of time the data is kept or the criteria used to determine the length of time. However, where such data is required for financial or legal compliance we may not be able to erase your data.
The information IBA collects will vary depending upon how you use the Websites and the Services. Data may be captured based on your user profile and your interaction in the site and such data may be utilized by algorithms to enhance your user experience or supplement personal data. IBA’s use and disclosure of the collected information will vary depending on the type of information IBA receives – i.e., Personal Information vs. Non-Personal Information.
If we intend to further process the personal data for any purpose other than that for which the personal data was obtained, we will provide you with information on that other purpose and with any relevant further information prior to the further processing. You will have the right to obtain from us information as to whether your personal data is being processed, and if so, (i) be informed of the purpose of the processing; (ii) be informed of the categories of personal data processed; (iii) be informed of the recipients or categories of recipient to whom the personal data have been or will be disclosed, if any; (iv) be aware, if possible, of the time period for which the personal data will be stored, or, if not possible, the criteria used to determine that time period; (v) be afforded the existence of the right to request from us, or a third-party, rectification or erasure of personal data or restriction of processing of your personal inform, or object to such processing; (vi) have the right to submit a complaint to us or the appropriate third-party; (vii) have the right to request the source of any information not collected directly from you; (viii) be notified if your personal data is utilized by algorithms to enhance your user experience or supplement personal data; and (ix) the right to obtain a copy of the personal data undergoing such processing and you agree to pay a reasonable fee if requested for a copy of your personal data being so processed providing obtaining such a copy does not adversely affect the rights and freedoms of others.
However, we may not provide notice as to third-party obtained information if providing such information would involve a disproportionate effort, in particular for processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the conditions and safeguards referred to in GDPR Article 89(1) or in so far as the obligation referred to in GDPR Article 14(1) is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases we will take appropriate measures to protect your rights, freedoms and legitimate interests, including making the general information publicly available but not identifying you specifically.
We may use Personal Information and Non-Personal Information as follows:
A. Personal Information. IBA may use your Personal Information to:
- Carry out the purposes for which you provided the information to IBA;
- Keep you apprised of events, news and information, and grants that you may find of interest;
- Customize the content or functionality of the Websites and/or the Services to your preferences;
- Attend to tasks relating to your interactions or transactions with IBA;
- Inquire as to whether you would like to receive any additional information regarding IBA’s activities, program offerings, etc.;
- Forward or otherwise provide updates, announcements and newsletters; and
- Respond to your communications, and communicate with you about the Websites, the Services and activities related thereto.
By using the Websites and/or the Services, you authorize IBA to transmit email and direct mail to you, call you, send push notifications to you, send you email messages, and otherwise contact you concerning IBA matters. You may, at any time, cancel such notifications. However, these notifications form part of the core serve we provide and cancelation may reduce the usefulness of our Website and Services.
If we disclose information to a third-party we will notify you before or at the time of disclosure. IBA may intentionally disclose your Personal Information only in the following instances:
i. Disclosures You Have Requested. IBA will provide your Personal Information to those entities and individuals that you have specifically designated (using the Websites, the Services or otherwise) to receive your information so that said entities and individuals can perform in accordance with your directives/wishes, contact you to address your questions and requests, etc. However, the Company is not responsible for the collection or maintenance of such information once it is in the hands of the designated entit(y/ies) or individual(s).
ii. Disclosures to Which You Have Consented. IBA may disclose your Personal Information if you have consented (whether expressly or implicitly) to said disclosure. By way of example only, if (i) you elect to participate in a sweepstakes sponsored by IBA and (ii) the official rules of the sweepstakes declare that IBA may publish the names of (and other information regarding) the sweepstakes entrants and/or winners, then, by virtue of your decision to participate in the sweepstakes, you are deemed to have consented to the official rules and the disclosure of your Personal Information in accordance with the rules.
iii. Disclosures to Trusted Third Parties. IBA may provide your Personal Information to third-parties who work on behalf of or with IBA, provided that (i) the disclosure is necessary or otherwise convenient in connection with assisting IBA in its operations and (ii) said operators work under confidentiality or similar agreements. We may share your personal data with third-parties, such as social media, payment processing, and software support service providers which will provide you with their privacy policies and terms and conditions for use.
B. Non-Personal Information. IBA may use your Non-Personal Information in several ways including, but not limited to:
- Administration of the Websites;
- Improvement of the Websites and the Services (including navigation thereof);
- Improvement of the programs and services offered by IBA;
- Analysis and development of advertisements and advertising campaigns;
- Providing you with special offers and promotions (and determinations regarding their effectiveness);
- Customization of the content or functionality of the Websites and the Services to suit your preferences; and
- Analysis of trends and usage.
IBA may use, share or disclose your Non-Personal Information only with your permission or to provide critical services which you have requested. For example, IBA may disclose your Non-Personal Information to employees, consultants and other professionals who IBA reasonably believes need such information in order to perform the tasks described in this Section 4.B. Additionally, IBA may combine your Non-Personal Information with other non-personal information collected by IBA and will only share the aggregated data with service companies and product providers for marketing and research purposes when you have given us explicit permission to do so.
5. IBA’S USE OF COLLECTION TECHNOLOGY AND ANALYTICS SERVICES
C. Artificial Intelligence. We may use automated processing, including artificial intelligence, machine learning, and other techniques to process your data. We will not use any type of automated processing if such processing produces legal effects concerning you or similarly significantly affects you unless such processing is: (i) necessary for entering into, or performance of, a contract between the you and us; or (ii) authorized by the State of Montana or US law to which we are subject and which also establishes measures to safeguard the your rights, freedoms, and legitimate interests; or results from your explicit consent. In the case of (i) or (iii), we will implement reasonable measures to safeguard your rights, freedoms, and legitimate interests, and, where and when possible, involve human intervention on our part to express your point of view and to contest the decision. In the case of the most sensitive data, such as race, ethnicity, gender, and the like, we will provide industry standard measures to safeguard your rights, freedoms, and legitimate interests.
6. PROTECTION OF INFORMATION
IBA is committed to protecting your Personal Information. Accordingly, IBA has adopted industry standard technical, administrative and physical procedures to help protect your Personal Information from loss, misuse, unauthorized access and alteration. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure (e.g., third party “hackers” may unlawfully intercept or access information or confidential transmissions). IBA wants you to feel confident using the Websites and the Services; but, as indicated in Section 1, above, IBA cannot ensure or warrant the security of any information you transmit to IBA and any such transmission is done at your own risk.
7. LINKS TO THIRD-PARTY WEBSITES
8. CORRECTION OF PERSONAL INFORMATION
IBA endeavors to keep your Personal Information current and accurate. You have the right to obtain from us without undue delay rectification of inaccurate personal data concerning you. Taking into account the purposes of our processing of your information and our regular business and technical processes, you have the right to supply incomplete personal data, including by means of providing a supplementary statement. Accordingly, IBA appreciates your courtesy in providing IBA with notice of any changes to your Personal Information via e-mail, telephone or postal mail at the addresses shown in Section 14, below. However, you have the right to request access to and rectification or erasure of personal data, or restriction of processing concerning your data, or to object to processing as well as the right to data portability.
You have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format of our choice and have the right to provide such information to any party of your choosing without restriction or hindrance from us. If practicable, and at our sole discretion, we may provide your personal data to a third-party you have explicitly designated in writing. Receiving your data has no impact or relationship to decisions you may make regarding erasure of your personal data nor adversely affect the rights of others.
You may at any time opt-in to have your Personal Information used by IBA for mailings, calls, etc. by notifying IBA via e-mail, telephone or postal mail at the addresses shown in Section 14, below. If, subsequent to opting in, you elect not to receive any future contacts from IBA, we will endeavor to remove your name from all of contact lists within ten (10) business days. However, information is sometimes difficult ‑ if not impossible ‑ to remove from all data sources and, accordingly, IBA can only promise to remove you from any lists that IBA controls using industry standard techniques.
The safety of children is very important to IBA, and IBA is committed to protecting the privacy of children. In this regard, (i) the Websites and the Services are directed to persons 18 years of age or older and (ii) IBA does not knowingly collect information from children under 18.
If you provide Personal Information to IBA through the Websites or the Services, you represent and warrant to IBA that you are 18 years of age or older, or of the legal age as legally specified in your jurisdiction. If you are under the age of 18 and not of the legal age within your jurisdiction to provide Personal Information, you may visit, browse and use the information on the Websites or the Services, but you may not submit any Personal Information to/through the Websites or the Services and you represent and warrant to IBA that you have the permission of your parent or legally designated guardian to use the Websites and the Services. If IBA becomes aware that you, or any user of the Websites and/or the Services, is under the age of 18 and has provided Personal Information, IBA will remove said information from its files and repositories within thirty (30) days unless complexity and number of requests is excessive, in which case the time period may be extended up to two additional months. In such case, you, or the subject, will be notified of the timetable for removal of Personal Information. No fee shall be charged for removal of this type of information.
10. NOTICE TO RESIDENTS OF SPECIFIC JURISDICTIONS
Residents of specific jurisdictions which may have specific rights outside or beyond those of the GDPR are entitled to request information about IBA’s compliance with specific jurisdictional standards. You may make such a request by sending an e-mail or letter to IBA at the following address:
International Association for Bear Research and Management
c/o Jennapher Teunissen van Manen
907 Jessie Way
Bozeman, MT 59715
13. GOVERNING LAW
14. QUESTIONS OR CONCERNS
Jennapher Teunissen van Manen