Nareit respects your privacy and is committed to protecting your personal data.
This Privacy Statement addresses Nareit’s practices regarding information collected from or about you when you use our website, www.reit.com (“Site”), use one of our mobile applications (each an “App”), obtain access to certain content, services, programs, products or benefits (each a “Product”), provide personal data in connection with one of our events, meetings, conferences, or forums (each an “Event”), or otherwise engage with us via telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media (“Offline Service”). The Site, Apps, Products, Events, and Offline Services are collectively referred to as the “Services.”
This Privacy Statement is incorporated into our Terms and Conditions of Use by reference, as if set forth fully therein. Your access and use of the Services will be deemed to indicate your acceptance to both this Privacy Statement and all of such Terms and Conditions of Use.
For any questions, Nareit can be contacted at firstname.lastname@example.org or by telephone at 202-739-9400.
1. INFORMATION COLLECTION
There are several ways we may obtain information about you, including through (A) information you provide to us directly; (B) information we automatically collect; and (C) information we receive from third parties. This includes data that identifies you personally whether directly ( i.e., your name) or indirectly (i.e., information about your online use).
A. Information You Provide
Nareit collects information from you when you choose to share it with us. This may include when you use our Site or App; register or create an online account with or through the Site or App; register as a speaker, attendee, or sponsor of a Nareit Event; provide us information in online forms, or registration or member forms; purchase Products or other services; request information from us; sign up for newsletters or our email list; use our service; enter into sweepstakes or other promotions; fill out a survey; request support; or otherwise communicate with or contact us.
Categories of information we may collect through the Services include:
- Identity Data, which includes first and last name or other similar identifiers and title.
- Contact Data, which includes address, email address and telephone numbers.
- Financial Data, which includes credit card, debit card or other payment card details, bank routing numbers, and related information (such as CVV, expiration date, and billing address).
- Transaction Data, which includes details about payments to and from you.
- Profile and Preference Data, which includes your username and password, your dining interests, dietary restrictions, food allergies, preferences, feedback and survey responses.
- Marketing and Communications Data, which includes your preferences in receiving marketing from us.
- Content Data, which includes any content which you upload through the Services, such as comments and other text or images that contain personal data.
Providing your personal information is completely voluntary. However, if you do not wish to provide certain information through the Services, you may be unable to participate in certain programs, activities, or Events, or access or use certain areas of the Site or App.
B. Information Automatically Collected
Please note that we automatically collect the following information about you:
- Computer or Device Information . We may automatically collect your Internet Protocol (“IP”) address or other unique identifier or information from the computer, mobile device, tablet or other device you use to access the Services, such as your location data, login data, browser or device information, and operating system.
- Usage Information . We may collect information about your use of the Services, including the date and time you visit the Services, the areas or pages of the Services that you visit; files you download; the amount of time you spend viewing or using the Services, the number of times you return to the Services, the domain name from which you accessed the Services, other click-stream or site usage data, emails that you open, forward or click-through to our Services, and other sites that you may visit.
- Our Third Party Service Providers . We use third party service providers to support our Site or Apps. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information.
To learn more about your advertising choices relating to the collection and use of your information, please see the “Your Choices and Opt Outs” section below.
C. Information Collected From Other Sources
We may acquire information from other sources as follows:
- From other trusted third-party sources to update or supplement the information that you provide or that we collect automatically. This includes, for example, information from public databases (which may include your demographic or other information to validate or update the information we collect from or about you).
- From our partners and service providers (including, for example, business partners, analytics vendors, advertising networks and search information providers).
We may use this information to help us maintain the accuracy of the information we collect, personalize your experience with the Services, target our communications so that we can inform you of products, services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.
D. Combination of Information
We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Services, as well as information collected offline, across other computers or devices that you may use, and from third party sources.
2. INFORMATION USE
A. Use by or for Nareit
Nareit may use the information it collects from and about you to:
- Respond to your inquiries, and contact and communicate with you when necessary (for example, we may contact you regarding an Event for which you have registered, or with information concerning renewal notices or outstanding balances);
- Confirm and process transactions (such as processing registrations or purchases);
- Facilitate and promote our Events (for example, we may provide a list of attendees, speakers, and sponsors in the App or at an Event), or to identify our members or registered users on the Site or App;
- Enhance your online experience, including to remember your online profile and preferences for future visits, or to create site content that is relevant to your interests;
- Review the usage and operations of the Services, develop new products or services, and perform statistical analysis to enhance or improve our content, products, and services;
- Provide you with customized content, targeted offers, and communications through the Site or Apps, via email, or across other websites, mobile applications, social media or online services;
- Contact you with information, newsletters and promotional materials from Nareit or on behalf of our partners and affiliates;
- Maintain internal records relating to feedback or complaints, and for other internal business purposes or to fulfill our recordkeeping requirements;
- Invite you to participate in voluntary surveys or research;
- To protect the security or integrity of the Site and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users, or for other internal purposes;
- Use your information where we are required by law; or
- For other purposes disclosed at the time you provide your information or otherwise with your consent.
Without limiting the foregoing, Nareit reserves the right, but not the obligation, to monitor any and all communications submitted through the Services or posted on the Site or App. Such voluntary information provided or posted by you may be collected and used by Nareit in accordance with this Privacy Statement.
For data subjects in the European Union, please see the section below titled “Additional EU Disclosures” for additional information, including our lawful basis for processing our data and your rights as a data subject.
B. How We Use Your Information for Interest-Based Advertising
We may display interest-based ads to you through Google, Facebook, Twitter, or other social media or online platforms or websites. These business tools allow us to personalize our ads to you based on your online experience with us, without having to share your personal data with these social media platforms. For example, we may do this by sharing hashed information (which converts your email or phone number to a unique string of numbers and letters) that the social media platform then matches against its own data for the limited purpose of serving advertisements directly to you. In this case, the matched and unmatched hashes are then deleted, and are not used for any other purpose.
We also may use information we collect through your use of the Services, from our advertising partners, and information we obtain from third parties to deliver advertising that is targeted to individuals with similar interests or demographics. This is typically done through the Facebook Custom Audiences, Twitter Tailor Audiences, or other similar business tools. These tools allow us to create groups based on actual or assumed shared interests, demographics, and/or factual characteristics based on anonymous and/or de-identified information to help us figure out what advertising may be most relevant. We do this without having to share your personal data with these third-party platforms.
Our use of your information for interest-based advertising purposes will be conducted in accordance with applicable law. For information on your choices with respect to interest-based ads, see the “ Interest Based Advertising Choices” section below
3. INFORMATION SHARING
Nareit may share the information we collect from and about you as described below.
A. Sharing of Information by You
The Services offer many ways to find, enjoy, and share content. Your activity in connection with the Services may include filling out surveys, reviewing and rating our Events, participating in online communities, “liking” or “sharing” our content to your social media accounts or pages or otherwise interacting with the Services. Any information you may disclose on our Site or App, in blogs, on message boards, in chat rooms, or on other public areas on the Site or App or other third-party websites, applications, or services that this Site or App may link to, becomes public information. Please exercise caution when disclosing personal information in these public areas.
B. Sharing of Information by Us
We may share your personal information with the following:
- Service Providers : We may share your information with third party service providers that provide business, professional or technical support functions for us (including to the extent necessary to process a payment and conduct related transactions), help us operate our business and the Services, or administer activities on our behalf.
- Nareit Event Sponsors : We may share your information with third parties that have sponsored a Nareit event for their marketing or other business purposes.
- Aggregate or Anonymous Non-Personal Information : We may also share aggregate, anonymous, or de-identified non-personal information with third parties for their marketing or analytics uses.
- Other : We also may share your information as disclosed to you at the time of collection.
While Nareit may undertake efforts to see that any third party to which Nareit shares or otherwise discloses personal information is under a contractual obligation to use the personal information solely for the purposes for which the information was disclosed, such third parties are independent third parties over which Nareit exercises no control. Nareit is not responsible for, and will not be liable for, the conduct, actions, omissions, or information handling or dissemination practices of third parties.
4. DATA SECURITY
We have put in place appropriate security measures to prevent information about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed; however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have put in place procedures to deal with any suspected data breach that will affect you and will notify you and any applicable regulator of a breach where we are legally required to do so.
In addition, to protect your personal information, never share your password with anyone, and if you feel that your password has been discovered, you should change it immediately by logging on to the Site or App and accessing your profile to change your password, or by contacting us at email@example.com .
5. DATA RETENTION
We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
6. ADDITIONAL EU DISCLOSURES
The following additional disclosures are provided for data subjects in the European Union, in accordance with applicable data protection law.
A. Our lawful basis for processing your personal data
Below are the types of lawful basis that we will rely on to process your personal data:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Consent means you have provided your informed consent to the processing of his or her personal data for one or more specific purposes.
- Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
B. Use of your personal data for marketing purposes
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.
To see how you can opt out of marketing communications, please see the section titled “Your Choices and Opt Outs”.
C. Rights of EU Data Subjects
Under certain circumstances, EU data subjects have rights under applicable data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests as soon as practicable and within one month. Occasionally it may take us longer than a month if your request is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.
To exercise your rights, please contact us at firstname.lastname@example.org .
7. YOUR CHOICES AND OPT OUTS
A. Cookies, Tracking Options and California Do Not Track Disclosures
For California Residents : Certain parts of our Site and App require cookies. You are free to adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.
B. Interest-Based Advertising Choices
To learn more about your choices for receiving interest-based advertising or to opt-out, please review the information below:
- DAA : To opt-out of such collection and use for interest-based advertising by the Digital Advertising Alliance (DAA) participating companies, please visit: http://www.aboutads.info/choices .
- EDAA : To opt-out from the use of information about your online activities for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) member companies, please visit: http://www.youronlinechoices.eu/ .
- NAI : To opt-out from the use of information about your online activities for interest-based advertising by Network Advertising Initiative (NAI) member companies, please visit: http://www.networkadvertising.org/choices/ .
C. Opting out of our marketing communications
8. THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES
The Site or App may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site or App, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.
9. Comments, Notices and User Content
Any materials or comments, including profiles, posted to any of our Web pages may be made public. Please refer to Section 6 of the Nareit Terms and Conditions for further detail concerning User Content and other materials submitted to the Site. As such, Nareit assumes no liability for the accuracy of such information, no duty to update or correct such information, and no liability for such communications arising under the laws of copyright, libel, privacy, obscenity, or otherwise.
10. DATA RELATING TO CHILDREN
The Services are not intended for users under the age of 18. Nareit does not knowingly collect personal information online from visitors in this age group. You must be at least 18 years of age in order to use the Services and to provide information through the Services, and by using the Services you represent to Nareit that you are 18 years of age or older.
11. CROSS BORDER TRANSFERS
Our Services are operated from the United States. If you are visiting from the regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and in other countries around the world.
You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If you are situated in the EU, whenever we transfer your personal data to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. In particular, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU, or may transfer to companies that are Privacy Sheild certified.
12. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code Section 1798.83 provides you with the right to request certain information regarding disclosure of your personal information to third parties for direct marketing purposes, including a description of the categories of personal information disclosed. In order to obtain such information, please email your request to email@example.com or write us at the address above.
14. Contact Us
Full name of legal entity: Nareit
Name or title: General Counsel
Email address: firstname.lastname@example.org
Postal address: 1875 I ST NW, Suite 500, Washington DC, 20006 United States of America
Telephone number: (+1) 202-739-9000
Dated: September 14, 2018