Effective Date: August 26, 2019
The United Soybean Board (“USB”) recently changed its Privacy Policy to, among other things, reflect compliance with its obligations under the European Union (EU) General Data Protection Regulation (GDPR). The following is a summary of key changes:
- Transparency: We’ve provided additional clarity regarding the information we collect from Customers, Visitors and Customer Business Contacts and how we process this information. We’ve also explained the choices and control individuals have over their information.
- Data Control: We’ve described how individuals can: (i) access, correct or delete their personal data from our systems; and (ii) provide or withdraw consent, as appropriate.
- Readability: We’ve updated our Privacy Policy to make it easier to understand by reorganizing it and using plain English.
We respect your privacy
USB 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: (i) our websites, or (ii) other data collection tools and applications (collectively, the “Sites”). The content provided on our Sites is for informational purposes only. This Privacy Policy contains important information regarding USB’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 Policy and consent to all actions that are consistent with this Privacy Policy. We encourage you to read this Privacy Policy in full to understand USB’s privacy practices before using the Sites or submitting any Personal Information thereon.
This Privacy Policy 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 Policy, we mean personal information or data we receive and record in the United States 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 nonpublic Personal Information. USB has no other entities or subsidiaries to which the scope of this Privacy Policy applies.
We do gather data in order to enhance your experience
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:
- Like many websites, ours may use “cookies.” A cookie is a small information file that some websites transfer to a user’s hard drive. We may use cookies to improve a user’s experience on the Sites, for example, to personalize features of the Sites for you, to analyze the traffic on the Sites and to maintain and make improvements based on the information we collect. The use of cookies has become standard practice for websites, but whether you choose to accept or decline these cookies is entirely up to you. Most browsers are initially set up to accept cookies. You may set your browser to reject cookies and to let you know when a cookie is being placed on your computer. If you refuse cookies, you may not be able to use some of the functionality of the Sites. Other third parties associated with the Sites may also use cookies in connection with the services and websites to which the Sites link. We do not control these cookies.
- 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 Policy, 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 webpages, ads or emails. We may use web beacons to deliver or communicate with cookies, to count users who have visited a webpage and 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.
Our Sites may include links to third-party websites
The Sites may contain links to websites operated by third parties whose information handling practices are different from USB’s. This Privacy Policy 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. USB is not responsible for the content or privacy practices of websites linked to the Sites or any other USB-sponsored websites that are not designed and developed by USB. 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.
Your personal data is used thoughtfully
We may use your Personal Information to:
- Operate the Sites and deliver information to you;
- Analyze and improve performance of the Sites;
- Learn what new information interests you;
- Respond to your requests;
- Conduct research about your opinion of USB and U.S. soy;
- Provide marketing materials to you and determine the effectiveness of the same;
- Perform customer service; and
- Otherwise manage our operations.
Your personal data will not be sold, rented or leased
While we do not sell, rent or lease any Personal Information collected through the Sites to third parties, USB may disclose information about you to the U.S. Soybean Export Council or the American Soybean Association as well as agents, such as vendors and service providers, acting on behalf of or in partnership with USB under instructions for the limited and specific purpose of assisting USB with its operations. In no event will that purpose be inconsistent with this Privacy Policy.
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 USB 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;
- In response to a valid subpoena;
- 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.
You have choices
When you provide Personal Information to us, you consent to our using that Personal Information in a manner consistent with this Privacy Policy. 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. 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 info@unitedsoybean.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 Policy 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 offenses, mental or physical health or biometric information. We have no intention of disclosing such Personal Information, but if for any reason USB needs to disclose “sensitive” Personal Information to any third party for uses other than those described in this Privacy Policy and except as required by law, 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.
We are good shepherds of your information
We do not share your Personal Information with any third party for the purpose of marketing or sending you advertisements not affiliated with USB, the U.S. Soybean Export Council or the American Soybean Association. 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 this Privacy Policy and will take reasonable and appropriate steps to ensure that and the third-party agent is processing Personal Information in a manner consistent with our obligations under this Privacy Policy. 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 this Privacy Policy. 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.
Your data is secure
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 info@unitedsoybean.org. We will respond in a timely manner to your request.
We commit to integrity, purpose limitation and access
We will not process Personal Information in a way that is incompatible with the purposes detailed in this Privacy Policy 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 info@unitedsoybean.org. We will respond in a timely manner to your request.
You can remove yourself from our subscriber list
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 info@unitedsoybean.org. 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.
Even if you opt out, we will retain your Personal Information for internal use only, such as for statistical analytics and legal compliance.
We do have a process for handling complaints
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 USB, we are committed to investigating and taking the necessary steps to resolve your concerns. If you have any questions, please send an email to our Privacy Manager at info@unitedsoybean.org.
Our Sites are not directed at 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 13. If you think that we have processed Personal Information from a child under the age of 13, please contact our Privacy Manager at info@unitedsoybean.org.
We may make changes to this Privacy Policy
We may revise or update this Privacy Policy at any time. The “Effective Date” at the top of this Privacy Policy reflects the date of the most recent revisions. The most current version of the Privacy Policy can be reviewed by clicking on the “Privacy Policy” link located at the bottom of each of our pages associated with the Sites. We encourage you to periodically review this link for the latest information on our privacy practices.
For more information, contact us
If you have questions about USB’s Privacy Policy, 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 info@unitedsoybean.org. You may also write us at United Soybean Board, Attn: Privacy Manager, 16305 Swingley Ridge Road, Suite 150, Chesterfield, MO 63017.