Privacy Policy

This privacy statement was last updated on October 7, 2021.

In this privacy statement, we explain how your personal information is collected, used, and shared by The Connected Commerce Council (“3C,” “we,” “us” and “our”) via https://connectedcouncil.org and other services controlled by 3C (the “Site”). We recommend you carefully read this privacy statement. You should not use the Site if you have any objections to our privacy statement, which is binding upon all users of the Site.

In our processing we comply with the requirements of applicable privacy legislation. That means, among other things, that:

• we clearly state the purposes for which we process personal information. We do this by means of this privacy statement;
• we aim to limit our collection of personal information to only the personal information required for legitimate purposes;
• we first request your explicit consent to process your personal information in cases requiring your consent;
• we take appropriate security measures to protect your personal information and also require this from parties that process personal information on our behalf;
• we respect your right to access your personal information or have it corrected or deleted, at your request.

If you have any questions, or want to know exactly what data we keep of you, please contact us through the contact methods provided at the end of this privacy statement.

1. Purpose and categories of data

“Personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, device, or household. Please see below for categories of personal information that we collect, the sources of the information, and the purpose for which the categories shall be used. Information about our use of cookies can be found on our Cookie Policy.

• Identifiers, which may include name, address, online identifiers, Internet Protocol address, telephone number, or email address. These are sourced directly from you or indirectly from you (e.g., from observing your actions on the Site). They are used to fulfill or meet the reason you provided the information, to contact you in relation to our Site, to respond to an inquiry, to screen for potential risk or fraud, to comply with legal obligations, to register you for an account, create a profile, send newsletters and advocacy information, or to provide services. For example, when you sign up for an account, you provide your first and last name, email address, and other identifying information. We disclose this information for business purposes to internet service providers and administrative service providers, including consultants.
• Professional or employment-related information, such as employment history, job title, company, or industry. We source this information directly from you. We use this information to register accounts, create profiles, or fulfill or meet the reason you provided the information. For example, we may request professional or employment-related information when registering an account for you. We disclose this information for business purposes to administrative service providers, including consultants.
• Geolocation data and Internet, technical, other similar network activity, which may include browser type; language preference; referring site; the date and time of page requests; usage and browsing history; device information, including device properties; search history; information on your interaction with our Site; and error logs. We source this information directly or indirectly from you (e.g., from observing your actions on our Site). We use this information to fulfill or meet the reason you provided the information, to screen for potential risk or fraud, to have a better understanding of how our visitors use our Site, to be able to generate reports on the trends relevant to the usage of our Site, to help with website administration, to analyze user activities on the Site, to collect information about our user base in general, to offer personalized products and services, or to improve our Site. We disclose this information for business purposes to administrative service providers, consultants, data analytics providers, and internet service providers. Please see our Cookie Policy for more information on our collection, use, and opt-out options.

Your decision to provide any personal information is voluntary. However, please note that, if you do not provide certain personal information, we may not be able to accomplish some purposes outlined in this privacy statement and you may not be able to use or access certain services on our Site.

2. Lawful bases for processing

We collect and use personal information when we have a lawful basis to do so. We process your personal information under the below lawful bases:

• At your direction and with your consent.
• To fulfill contracts we might have with you.
• For legitimate business purposes. This includes, but is not limited to, legal compliance and the purposes described above.
• To comply with a legal obligation. For example, to comply with the law or respond to a legal process or lawful request, including from law enforcement and government agencies.

3. Sharing with other parties

We share or disclose your personal information to third party service providers, including consultants, who are located in the US and in Europe, for the following purposes:

• Helping us to monitor visitor behavior
• Advertising and marketing 
• Network management
• Sending emails and other communications
• Collecting user preferences 

We may share or transfer your information in the course of any direct or indirect reorganization process including, but not limited to, mergers, acquisitions, divestitures, bankruptcies, and sales of all or a part of our assets. Your information may be shared following completion of such transaction and/or during the assessment process pending transfer. If transferred in such a case, your information would remain subject to this privacy statement or a privacy policy that, at a minimum, protects your privacy to an equal degree as this privacy statement.

We also disclose personal information if we are required by law or by a court order, in response to a law enforcement agency, to the extent permitted under other provisions of law, to provide information, or for an investigation on a matter related to public safety.

4. How we respond to Do Not Track signals

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. Our Site therefore does not respond to and does not support the DNT signals and does not respond to them.

5. Cookies

Our website uses cookies. For more information about cookies, please refer to our Cookie Policy on our Cookie Policy webpage.

6. Security

We are committed to the security of personal information. We take appropriate security measures to limit abuse of and unauthorized access to personal information. This ensures that only the necessary persons have access to your data, that access to the data is protected, and that our security measures are regularly reviewed. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Site. We may post a notice via our Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

7. Third party websites

This privacy statement does not apply to third party websites connected by links on our website. We cannot guarantee that these third parties handle your personal data in a reliable or secure manner. We recommend you read the privacy statements of these websites prior to making use of these websites.

8. Amendments to this privacy statement

We reserve the right to make amendments to this privacy statement and will update the date at the top of the privacy statement when we do so. It is recommended that you consult this privacy statement regularly in order to be aware of any changes. In addition, we will actively inform you when we make a material update to the privacy statement by prominently posting the changes on our Site or by using the contact information you have on file with us. By continuing to use our Site you are agreeing to be bound by any changes or revisions made to this Privacy Statement.

9. Your Rights

If you have any questions or want to know which personal information we have about you, please contact us through the methods provided at the end of this privacy statement. Please make sure to always clearly state who you are, so that we can be certain that we do not modify or delete any data of the wrong person. We shall provide the requested information only upon receipt of a verifiable request. Depending on your residence, the rights available to you may differ in some respects. We will respond to any rights request in accordance with local legal regulations.

9.1 Right of access

• You may have the right to get confirmation about whether or not your personal information is being processed. If so, you have the right to access the personal information and other information, such as the purposes, the categories of personal information, the recipients (or categories of recipients) to whom the personal information have been or will be disclosed, for particular recipients in third countries or international organizations, where possible, the predicted period that the personal information will be stored, or, if not possible, the criteria used to determine that period, your rights, etc.
• Where feasible and permitted by law, we will provide a copy of the personal information we are processing. For any further copies, we may charge a reasonable fee based on administrative costs. If you make the request by electronic means, and unless otherwise requested, the information shall be provided in electronic form.

9.2 Right to rectification

You may have the right to the erasure of your personal information in certain circumstances. For examples, see below.

9.3 Right to erasure (“right to be forgotten”)

You may have the right to the erasure of your personal information in certain circumstances. For examples, see below.

• Your personal information is no longer necessary for the purposes for which they were processed
• You withdraw your consent on which the processing is based, and we have no other legal ground for the processing
• You object to the processing and there are no overriding legitimate grounds for the processing
• For the establishment, exercise or defense of our legal claims

This right shall not apply to the extent that processing is necessary for the below purposes.

• For exercising the right of freedom of expression and information
• For compliance with a legal obligation which requires processing by a law to which we are subject
• For the performance of a task carried out in the public interest
• Your personal information has been unlawfully processed
• Your personal information has to be erased for compliance with a legal obligation to which we are subject

9.4 Right to restriction of processing

You may have the right to restrict the processing for the below reasons.

• You contest the accuracy of your personal information, for a period enabling us to verify the accuracy of the personal information
• The processing is unlawful and you oppose the erasure of the personal information and request the restriction of their use
• We no longer need the personal information for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims
• You exercised your right to object to processing pending the verification whether our legitimate grounds override yours

9.5 Right to data portability

You may have the right to receive the personal information that you have given us, in a structured, commonly used and machine-readable format.

9.6 Right to object

You may have the right to object, on grounds relating to your particular situation, to processing of your personal information which is based on our legitimate purposes. We will stop processing the personal information unless we have compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. If personal information is processed for direct marketing purposes, including profiling, you may object at any time.

9.7 Automated individual decision-making, including profiling

You may have the right not to be subject to a decision based solely on automated processing, including profiling, except under certain exceptions under local law.

9.8 Right to withdraw consent

Where the processing of personal information is based on your consent, you may have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.

9.9 Right to anonymity

You may also have a right to request anonymity. This means that your personal information would not be collected or processed. If you choose to exercise this right, we may not be able to provide you with your requested services.

9.10 Right to lodge a complaint with a supervisory authority

You may have the right to lodge a complaint with a supervisory authority.

10. Your California Privacy Rights

If you are a California resident, you may be entitled to the below rights. You can exercise your rights by contacting us using the details at the bottom of the privacy statement. Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information. You may designate an authorized agent to make a request on your behalf. Such authorized agent must have permission to submit requests on your behalf. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

Additionally, please note that we have not sold consumers’ personal information in the preceding 12 months, we have not shared your personal information with third parties for their direct marketing purposes, and we have not sold the personal information of children under 16 years old.

10.1 right to know what personal information is being collected about you

A consumer shall have the right to request that a business that collects personal information about the consumer disclose to the consumer the following:

1. The categories of personal information it has collected about that consumer.
2. The categories of sources from which the personal information is collected.
3. The business or commercial purpose for collecting or selling personal information.
4. The categories of third parties with whom the business shares personal information.
5. The specific pieces of personal information it has collected about that consumer.

10.2 The right to know whether personal information is sold or disclosed and to whom

A consumer shall have the right to request that a business that sells the consumer’s personal information, or that discloses it for a business purpose, disclose to that consumer:

1. The categories of personal information that the business collected about the consumer.
2. The categories of personal information that the business sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
3. The categories of personal information that the business disclosed about the consumer for a business purpose.

10.3 The right to equal service and price, even if you exercise your privacy rights

We shall not discriminate against a consumer because the consumer exercised any of the consumer’s privacy rights, including, but not limited to, by:

1. Denying goods or services to the consumer.
2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
3. Providing a different level or quality of goods or services to the consumer, if the consumer exercises the consumer’s privacy rights.
4. Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
   However, nothing prohibits us from charging a consumer a different price or rate, or from providing a different level or quality of goods or services to the consumer, if that difference is reasonably related to the value provided to the consumer by the consumer’s data.

10.4 The right to delete any personal information

1. A consumer shall have the right to request that a business delete any personal information about the consumer which the business has collected from the consumer.
2. A business that receives a verifiable request from a consumer to delete the consumer’s personal information pursuant to subdivision (a) of this section shall delete the consumer’s personal information from its records and direct any service providers to delete the consumer’s personal information from their records.
3. A business or a service provider shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is necessary for the business or service provider to maintain the consumer’s personal information in order to:
   1. Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
   2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
   3. Debug to identify and repair errors that impair existing intended functionality.
   4. (Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
   5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
   6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
   7. To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
   8. Comply with a legal obligation.
   9. Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

A list of the categories we have disclosed for a business purpose in the preceding 12 months:

• Identifiers
• Professional or employment-related information
• Geolocation data and Internet, technical, or other similar network activity

11. Children

Our website is not designed to attract children and it is not our intent to collect personal information from children under the age of consent in their country of residence. We therefore request that children under the age of consent do not submit any personal information to us.

12. International Transfer of Personal Data

If you choose to provide us with personal information, we may transfer that personal information to our affiliates and other third parties. We may also transfer your personal information across borders, from your country or jurisdiction to other countries or jurisdictions in accordance with legal requirements. These other countries, such as the U.S., may not have the same data protection laws as the country you are visiting from and may not afford many of the rights conferred upon data subjects in your country. By using the Site, participating in any of the services, and/or providing us with personal information, you acknowledge this transfer, which may not offer the same level of data protection as the country where you reside, in accordance with the terms of this privacy statement.

3C primarily uses European Union Commission Standard Contractual Clauses for data transfers from the European Union, the EEA, the UK and Switzerland to countries outside the EEA (including the UK). For transfers between other jurisdictions, 3C may rely on other legal mechanisms for international transfer, as appropriate under the relevant law.

13. Contact details

Connected Commerce Council
Attn: Privacy Office
1701 Rhode Island Ave NW, Washington D.C. 20036
United States
Website: https://connectedcouncil.org
Email: info@connectedcouncil.org

Phone number: 202-769-3003