Effective Date: September 2, 2016
U.S. Soybean Export Council (“USSEC”) respects your privacy and is committed to protecting your privacy in connection with the collection, retention, use, transfer, and other processing (“processing”) of your Personal Information which may occur through our websites, http://ussec.org and http://ussoy.org (the “Sites”). The content provided on our Sites is for informational purposes only. This Privacy Statement contains important information regarding USSEC’s information handling practices and the choices it offers individuals with respect to the processing of their personal information. If you choose to use the Sites, you are telling us you have read, fully understand, and accept the information handling practices summarized in this Privacy Statement and consent to all actions that are consistent with this Privacy Statement. We encourage you to read this Privacy Statement in full to understand USSEC’s privacy practices before using the Sites or submitting any Personal Information thereon.
This Privacy Statement applies to our processing of the Personal Information that we obtain from your visit to the Sites. When we use the term “Personal Information” in this Privacy Statement, we mean personal information or data we receive and record in the United States from the European Union (“EU”), Iceland, Liechtenstein, and Norway, that is processed from your visit to the Sites and that identifies, or can be used by us or on our behalf to identify, an individual. This can be contact information, such as your name, home or other physical address, email address, telephone number, fax number, organization name, and/or job title. Personal Information does not include encoded information, aggregate information, anonymized information, or information that is publicly available and not combined with non-public Personal Information. USSEC has no other entities or subsidiaries to which the scope of this Privacy Statement applies.
The operations of USSEC require the processing of personal data received from the EU, Iceland, Liechtenstein, and Norway. We adhere to the Privacy Shield Principles (“Principles”), as set forth by the U.S. Department of Commerce and the European Commission in the EU-U.S. Privacy Shield Framework (“Privacy Shield Framework”) regarding the processing of Personal Information from the EU Member States, Iceland, Liechtenstein, and Norway. We have certified that we adhere to the Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability. Our self-certification can be found at https://www.privacyshield.gov/list. For more information about the Privacy Shield Framework, the Principles, and the requirements for participating companies and organizations, such as USSEC, please visit https://www.privacyshield.gov/Program-Overview.
We may collect Personal Information from you on the Sites, including:
Personal Information You Voluntarily Provide. If you voluntarily provide us with Personal Information, we may collect this Personal Information. You may voluntarily provide this information to us in a variety of ways, including by subscribing to receive news updates, event information, and useful content that you have requested.
Personal Information We May Automatically Collect. We may use various technologies to collect information about you when you visit the Sites. These technologies may include:
- Internet Protocol Addresses. The Sites may use Internet Protocol (“IP”) addresses. An IP address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, web servers can identify your computer by its IP address. In addition, web servers may be able to identify the type of browser and/or type of computer you are using. We log IP addresses and related information for the purposes of system administration, to assess the traffic on the Sites, and to maintain and make improvements to the Sites. We do not link IP addresses to your Personal Information, but we can and will use IP addresses to identify a user when we feel it is necessary to enforce compliance with this Privacy Statement, to protect the Sites, customers, or others, or to comply with applicable laws.
- Web Beacons. Web beacons are small files that communicate with third parties and are embedded in web pages, ads, or in emails. We may use web beacons to deliver or communicate with cookies, to count users who have visited a web page, to understand usage patterns or other third party functionality. We also may use web beacons to learn if emails have been opened, acted on, or forwarded. We also may include web beacons in newsletters, brochures, and flyers that we send to subscribers in order to count how many newsletters, brochures, and flyers have been opened or read. You can disable the ability of Web beacons to store cookie information by declining cookies. Our web beacons do not collect, gather, monitor, or share any Personal Information about visitors to our Sites. They are merely designed to compile anonymous, aggregated information about collective usage of the Sites.
- Other Technologies. Examples of other technologies we may use to provide better service to you when visiting the Sites include:
- Web Session Variables. Information that is passed from one web URL to another as you browse.
- Browser plug-ins/add-ons. Additional web components that may need to be installed to enable certain web features on the Sites. You have the option not to install these components.
Third Party Links
The Sites may contain links to websites operated by third parties whose information handling practices are different from USSEC’s. This Privacy Statement does not apply to any information collected from you through such links or that you may provide on the websites you reach by utilizing those links. USSEC is not responsible for the content or privacy practices of websites linked to the Sites or any other USSEC-sponsored websites that are not designed and developed by USSEC. You are encouraged to use common sense when using our Sites and review the privacy practices of each website you elect to visit before submitting your Personal Information.
Please be advised that if you disclose Personal Information through public forums, message boards, or blogs whose access is provided by USSEC, this information may be collected and used by others. We do not monitor these public spaces and take no responsibility for the security or confidentiality of any information posted thereon.
Notice of Use of Information
We may use your Personal Information to:
- Operate the Sites and deliver to you the products, services, and information;
- Analyze and improve performance of the Sites, our products, and our services;
- Learn what new products, services, or information interest you;
- Respond to your requests;
- Conduct research about your opinion of USSEC, the Sites, and our products, services, and information;
- Market and advertise our products, services, and information to you and determine the effectiveness of the same;
- Perform customer service; and
- Otherwise manage our operations.
While we do not sell, rent, or lease any Personal Information collected through the Sites to third parties, USSEC may disclose information about you to agents, such as vendors and service providers, acting on behalf of USSEC under instructions for the limited and specific purpose of assisting USSEC with its operations. In no event will that purpose be inconsistent with this Privacy Statement. In all cases, these agents have entered into confidentiality agreements with USSEC and may only use this information in connection with providing services to USSEC.
Sometimes a law, court order, or other judicial or administrative process requires us to provide Personal Information to a government authority or party to a private lawsuit. While USSEC will only provide such information that we in good faith believe is required to comply with the law, order, or other legal process, we may disclose certain Personal Information if:
- The Commerce Department requests it;
- National security or law enforcement requirements mandate it;
- We are required to bring, or defend against, litigation or any regulatory proceeding between, or relating to, you and us; and
- We have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Sites, or anyone else who could be harmed by such activities.
When you provide Personal Information to us, you consent to our using that Personal Information in a manner consistent with this Privacy Statement. You have choices about whether we use your Personal Information to communicate with you and, if we do communicate with you, what form that communication takes. We will use your Personal Information as described in the “Notice of Use of Information” section of this Privacy Statement. If you wish for us to stop using your Personal Information for any of the uses described, you can write to us at the address provided in our Contact Information or contact our Privacy Manager at firstname.lastname@example.org and tell us that you no longer consent to such use (that is, you “opt-out” of such use). We will not disclose your Personal Information to any third party for uses other than those described in this Privacy Statement without first providing you with notice and a clear choice to “opt-out” of such disclosure.
We do not seek, nor do we knowingly process, so-called “sensitive” Personal Information. This category of Personal Information is more sensitive and relates to, for example, an individual’s race, sexual orientation, criminal allegations or offences, trade union memberships, their mental or physical health, or their biometric information. We have no intention of disclosing such Personal Information, but if for any reason USSEC needs to disclose “sensitive” Personal Information to any third party for uses other than those described in this Privacy Statement, it will first provide you with notice and seek your affirmative express (“opt-in”) consent prior to such disclosure, except in a very limited set of exceptional circumstances.
Accountability for Onward Transfer
We do not share your Personal Information with any third party for the purpose of marketing or sending you advertisements for products, services, or information not affiliated with USSEC. Prior to making any disclosures to third party agents, we will attempt to ascertain that such third parties are providing at least the same level of privacy protection as is required by the Principles and will take reasonable and appropriate steps to ensure that and third party agent is processing Personal Information in a manner consistent with our obligations under the Principles. We will require any third party agents to notify the organization if that agent determines it is unable to provide the same level of privacy protection as is required by the Principles. To the extent that we are made aware of the unauthorized processing of your Personal Information, we will take reasonable and appropriate steps to stop and remediate the unauthorized processing.
We are concerned with the security of your Personal Information and consider the protection of Personal Information we receive from visitors to our Sites as critical to our organization’s mission of promoting soy and soybean products worldwide. We deploy a combination of reasonable and appropriate physical, technological, and administrative safeguards to protect against the loss, misuse, unauthorized access, disclosure, alteration, and destruction of any Personal Information we receive from you. We follow generally accepted security standards in our operations to protect the security of your Personal Information, both internally and from outsiders, and to ensure the integrity of the Personal Information we process, taking into account the relative risks involved and the nature of the Personal Information in question. Unfortunately, with any transmission over the Internet, there is always some element of risk involved in submitting Personal Information. If you have any questions about the security of your Personal Information, you can contact our Privacy Manager at email@example.com. We will respond in a timely manner to your request.
Integrity, Purpose Limitation, and Access
We will not process Personal Information in a way that is incompatible with the purposes detailed in this Privacy Statement and will take all reasonable steps necessary to ensure that your Personal Information is reliable, accurate, complete, and current. If you believe that the Personal Information you have voluntarily provided to us is, or has become, unreliable, inaccurate, incomplete, or untimely, you may review, revise, correct, or update any of the Personal Information we may have about you, except where the burden or expense of providing access to such review, revision, correction, or update would be disproportionate to the risk to your privacy, where the rights of persons other than you would be violated, where the organization’s confidential commercial information would be compromised, where it would interfere with the execution or enforcement of the law or with a private cause of action, or where it would breach a legal or other professional privilege or obligation. If you have any questions about access to your Personal Information, you can contact our Privacy Manager at firstname.lastname@example.org. We will respond in a timely manner to your request.
If you do not want us to use or continue using your Personal Information to communicate with you, you may request that we not do so (“opt-out”) by following the procedures described below.
- Opting-Out at Signup: When you provide us with Personal Information, you will be given a choice as to whether to receive promotional information from us.
- Opting-Out of Further Communications: Please send your opt-out request to our Privacy Manager at email@example.com. Place the word “UNSUBSCRIBE” in your request to us. We will respond in a timely manner to your request. You can also stop receiving promotional email messages from us by following the instructions provided in any such message you receive.
We will retain your Personal Information for as long as needed to meet the uses described in the “Notice of Use of Information” section of this Privacy Statement. In addition, even if you opt-out, we will retain your Personal Information for internal use only, such as for statistical analytics and legal compliance.
Complaint Handling Process / Independent Recourse Mechanism
We are committed to ensuring that complaints concerning your Personal Information are investigated and resolved. For this reason, we have developed a complaint handling procedure. It is our intention to resolve all privacy-related complaints through this procedure. We respect your privacy and if you submit a concern to USSEC, we are committed to investigating and taking the necessary steps to resolve your concerns.
The following is a summary of how our complaint handling process works. If you have any questions, please send an email to our Privacy Manager at firstname.lastname@example.org.
- Complete and submit the online Privacy Complaint Form or fax it to 1-636-449-1292.
- You will receive a communication within five (5) days from USSEC acknowledging receipt of your complaint.
- You will receive a communication from a USSEC employee assigned to investigate your concern within five (5) days from the day you receive the communication from USSEC acknowledging receipt of your complaint.
- USSEC will conduct an investigation into your complaint (during this process, you may receive additional communications from the designated USSEC investigator).
- The designated USSEC investigator will contact you within twenty (20) days from the date he/she first contacted you with a proposed resolution to your concern.
- If you agree with the proposed resolution, you and the investigator will work together to close out the complaint. If you do not agree, the matter will be escalated to USSEC’s Privacy Manager.
- If you and the investigator have not resolved your concern, USSEC’s Privacy Manager will take steps to resolve the matter. Within ten (10) days of the escalation, USSEC’s Privacy Manager will contact you to propose a resolution.
- If you agree to the resolution, you will work with the Privacy Manager to close the matter.
- If you and the Privacy Manager do not agree to a resolution, you will be offered the opportunity to take the matter to an independent recourse mechanism at no cost to you.
- Because there may be instances where resolution through our internal complaint handling process is not achievable, or where you may wish to pursue independent resolution mechanisms, we have agreed to participate in the independent resolution mechanism provided by the Judicial Arbitration and Mediation Services (“JAMS”).
- For more information about the independent resolution of your complaint, please visit https://www.jamsadr.com/eu-us-privacy-shield.
- To file a complaint with JAMS, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.
Policy Regarding Children
The Sites are not directed to children under the age of 13, and we do not seek, nor do we knowingly process, Personal Information from children under the age of thirteen (13). If you think that we have processed Personal Information from a child under the age of thirteen (13), please contact our Privacy Manager at email@example.com.
Changes to This Privacy Statement
If you have questions about USSEC’s Privacy Statement, our information handling practices, or any other aspect of privacy and security of your Personal Information, please send an email to our Privacy Manager at firstname.lastname@example.org or fax your question to 1-636-449-1292. You may also write us at U.S. Soybean Export Council, 16305 Swingley Ridge Road, Suite 200, Chesterfield, MO 63017.