Effective Date: March 30, 2021
The mdrtacademy.org and related websites (collectively, “Sites”) are developed and maintained by The MDRT Academy Corporation (hereinafter “The MDRT Academy”, “we”, “our” or “us”), a nonprofit organization. When you as a visitor or member (“you” or “your”) visit Sites, or use our mobile application or the services we provide (collectively, “Services”), we may collect and use certain information about you.
2. Personal Information
4. Information We Collect
We only collect information that is reasonably necessary for us to provide the Sites and Services. We collect information about you when you interact with our Sites and Services. We may also collect information about you from our registration vendors and our affiliates. When you use our Sites and Services, we collect information about one or more devices associated with you that you use to access the Sites and Services, such as a computer, mobile phone or tablet. We may collect, store and use information you provide to us from one or more devices associated with you when you use our Sites and Services, including when you log in to the Sites or Services from one or more devices, download and install our mobile app, register for an account, complete a web form, add or update your account information or otherwise correspond with us regarding the Sites and Services.
Collected information may include:
- Mailing address
- Email address
- Phone number
- Language preference
- Languages you speak or read
- Company affiliation
- Broker-dealer affiliation
- Agent/company ID
- Professional designations
- Messaging ID (e.g., WeChat ID)
- Company name
- Job title/position
- Date of first insurance license
- Mentoring participation
- Production data and verification of that information
- Descriptions that you provide of your business, your expertise, and your monthly and annual goals
- Photographs containing your image or likeness
- Event registration and attendance history
- Product/service/membership purchase history
- Records and copies of your correspondence (including email addresses), if you contact us
- Information that you provide by filling in webforms on our Sites. This includes information provided when creating an online account, purchasing our Products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, report a problem with our Sites, products or Services, or otherwise communicating with us
- Registering for an event
- Your responses to surveys that we or our service providers might ask you to complete for research purposes
- Your search queries on the Sites
- In stores (parent, subsidiary and affiliate brands)
- On mobile applications (parent, subsidiary and affiliate brands)
- When communicating with customer service/support
- Through participation in loyalty/rewards programs
- Third-party websites and mobile applications (e.g., websites that share information with us or advertising partners regarding online activities)
- Fulfillment and delivery service providers
- Social media companies
- Other service providers
- Responding to employment opportunities
5. Information Collected Automatically
Subject to applicable exceptions, we will obtain your consent before collecting, using and disclosing your information for the specified purposes. In addition to circumstances in which you consent to the use of your Personal Information, the Personal Information we collect may be used or processed where we have a legitimate interest in or other legal basis for processing such data. In some situations, the collection of Personal Information may be required for the operation of the Sites and Services or to provide certain services or products. As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Sites, including, but not limited to, traffic data, geolocation data, logs and other communication data, and the resources that you access and use on the Sites, and
- Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Sites, the amount of time you spent on our Sites, and the pages you viewed while on our Sites.
We use several types of cookies on the Sites and Services:
Functionality Cookies. These cookies are used to remember choices you make when you use our Sites, such as your country, type of business or resource viewing history. The purpose of these cookies is to provide you with a more personalized experience.
Analytics and Performance Cookies. These cookies are used to collect information about traffic to the Sites and how users use the Site. The information is aggregated and anonymous and does not identify any individual visitor. It includes the number of visitors to our Sites, the pages they visited and other similar information. We use this information to help operate, maintain and improve our Sites.
Social Media Cookies. These cookies are used when you share information using a social media sharing button on the site or engage with our content on or through a social network such as Facebook or Twitter. The social network will record that you have done this.
You can typically remove and reject cookies from MDRT with your browser settings. For step-by-step instructions, please check your browser’s help section. The following are links for several popular browsers: Chrome, Firefox and Internet Explorer. If you remove or reject our cookies, it could affect how our websites work for you.
Local Storage Cookies. Certain features of our Sites may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Sites. Local storage cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Sites and our emails may contain small electronic files known as web beacons (also referred to as clear GIFs, pixel tags and single-pixel GIFs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pixel Tracking. In addition to using Cookies, the Sites may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Sites from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Sites. If you visit our Sites, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research and other activities.
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
IP Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Sites. These server logs may include information such as which pages of the Sites you visited, your internet protocol (“IP”) address, browser type and other information on how you interact with the Sites. These log files are generally deleted periodically.
Many internet browsers and mobile devices allow you to block the transmission of information, such as your IP address or location information, or to block the installation of cookies. You may choose to enable these options. For step-by-step instructions, please check your browser’s help section. Here are links for popular browsers: Chrome, Firefox and Internet Explorer. However, enabling these options may prevent you from using many of the core features and functions available on our Sites and Services.
Keystrokes and Cursor Movement. We or our service providers may keep track of and/or collect the keystrokes (but not the specific information entered) and cursor movements of visitors to our Sites, but this information is anonymous and, at the time of collection, we do not directly associate or attempt to associate this information with you as an identifiable individual. We use this information solely for the purpose of improving our website to improve our customers’ user experience (e.g., improving navigation, readability, etc.).
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.
6. How We Use Your Information
Subject to applicable exceptions, we will obtain your consent before collecting, using or disclosing your Personal Information for the specified purposes. In addition to circumstances in which you consent to the use of your Personal Information, the Personal Information we collect may be used or processed where we have a legitimate interest in or other legal basis for processing such data. In some situations, the collection of Personal Information may be required for the operation of the Sites and Services or to provide certain services or products. The information we collect may be used or processed for the following purposes:
- To serve the functions of the Sites and Services
- To manage everyday business needs, such as administration and improvement of the Sites
- To analyze the Sites’ performance and functioning
- To prevent fraud, to enforce the Sites’ Terms, to comply with all applicable laws and corporate reporting obligations, and to enforce our agreements
- To analyze how you use the Sites and Services and to perform other market research
- To communicate with you about our and our affiliates’ products and services
- To facilitate your interaction through our Sites and Services with other consumers; and
- To send you further notices, promotions, or other marketing materials regarding our Sites and Services, our products and services, and our affiliates’ products and services.
We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
- To present our Sites and Mobile App and its contents to you
- To provide you with information and respond to your questions on products or Services that you request from us and information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you
- To provide you with the products, services or information that you have requested
- To process (as applicable) product and/or service fees, subscription fees, professional fees, membership dues, registration fees, donations, examination fees, credential and designation fees, and payments, refunds and reimbursements for any products or services that you choose to purchase from us (though we do not receive your credit or debit card number for any of the foregoing)
- To provide you with notices about your account, including expiration and renewal notices
- To notify you about information regarding or changes to our Sites, our policies, terms, or any products or Services we offer or provide, or regarding your account
- To process your account application and any changes to your account information
- To process Personal Information or other information that you submit through to us
- To allow you to participate in interactive features on our Sites
- To contact you about our products and services that may be of interest to you
- To provide access to restricted parts of our Sites, e.g., areas accessible if you have a user account
- To enhance and improve our Products and Services, for example, by performing internal research, analyzing user trends, or measuring demographics and interests
- For internal purposes, such as Sites and system administration or internal audits and reviews
- For analyzing how the Services are used, diagnosing Service or technical problems, maintaining security and personalizing content
- To operate, maintain and provide to you the features and functionality of the Services
- To provide statistics about the usage levels of the Sites and other related information to our service providers
- To notify you of data privacy incidents or provide you with legally required information
- To contact you regarding a sweepstakes, contest or promotion in which you have participated
- To request your participation in ratings, reviews, surveys, focus groups or other initiatives which help us to gather information used to develop and enhance our products and Services
- To determine eligibility for membership, credentials, designations or volunteer opportunities
- To evaluate your performance on continued learning courses and assist you in the tracking of your progress
- For examination or event registration, scheduling, event attendance, administration and related purposes
- To fulfill any other purpose for which you provide Personal Information
- In any other way we may describe and for which we obtain your consent when you provide the information and you give your consent
We may use your Personal Information to develop a personal profile about you. We may share your information with our affiliates, which may contact you to provide information regarding mentoring or eligibility for membership in MDRT. If you notify us that you do not wish to be contacted for such purposes, we will not send you marketing information.
7. How We Share Your Information
Disclosures to Affiliates. We may share your information, including your Personal Information, with our affiliates to understand and develop the demographic makeup of our members, provide you with offers from our affiliates, and coordinate the services that are offered and provided to you by us and our affiliates.
We also may share your information with third-party service providers who perform services and functions on our behalf to support our interactions with you including, for example, providing our products and services, processing your purchases, administering surveys or contests, or communicating with you. These third parties are only allowed to process the information that we share with them in accordance with our express instructions and in compliance with your local law. Where it is necessary for Personal Information to be provided to a third party in connection with the provision of a service to us, we will take reasonable steps to prevent the unauthorized use or unauthorized disclosure of your Personal Information.
Disclosures to Service Providers. We may share your Personal Information with third parties for the purpose of providing or improving the Sites or Services to you. We may share your Personal Information with third-party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to outbound and/or inbound communications, data analysis, screening checks, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, providing search results, and processing credit card payments. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).
Event-Related Disclosures. From time to time, we may run contests, special offers or other types of special promotions (“Promotions”), possibly together with a third-party Service Provider. If you provide information to such Service Providers, you give them permission to use it for the purpose of that Promotion and any other use to which you consent. We cannot control such third parties’ use of your information. If you do not want your information to be collected by or shared with such third parties, you can choose not to participate in the Promotion.
We may also provide to third parties, including other businesses and members of the public, aggregated statistical data showing general usage patterns and statistics, interactions and transactions with our Sites and Services. This data does not personally identify you or provide specific information about individual usage.
In addition, we may disclose information about you
- If we are required to do so by or to comply with law, law enforcement, or legal or government process
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or other harm, or in connection with an investigation of suspected or actual illegal activity
- If this is necessary to protect the vital interests (life, health or safety) of a person or another person
- To protect our property, services and legal rights
- To prevent fraud against us, our affiliates or business partners
- To evaluate or complete any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company
- Data storage or hosting providers for the secure storage and transmission of your data
- Database and software service providers for the management and tracking of your data
- Technology providers who assist in the development and management of our Sites
- Identity management providers for authentication purposes
- Legal and compliance consultants, such as external counsel, external auditors or tax consultants, or to support auditing, compliance and corporate governance functions
- Payment solution providers for the secure processing of payments you provide to us
- Manufacturers, retailers and wholesalers for submission, processing and management of rebates, discounts, offers, loyalty rewards, and the like
- Fulfillment and shipping vendors for the fulfillment of our Products and Services
- Survey and research providers who perform studies on our behalf
- Publishers and learning providers who develop products on our behalf
- Learning technology and online event providers for the delivery and improvement of web events and learning programs and the tracking of your progress
- Examination providers for the scheduling and delivery of credential and designation examinations
- Digital credential providers for the delivery of digital badges earned through your participation in learning programs
- Advertising partners, including social media providers, for the delivery of targeted advertisements
- Our volunteers or committee members who perform various functions on our behalf
Disclosure of De-Identified Personal Information. We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Sites. It may be utilized to measure the number of visits to our Sites, average time spent, number of pages viewed and to monitor various other Sites statistics. This monitoring helps us evaluate how visitors use and navigate our Sites so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose.
8. Data Access, Correction, Deletion and other Rights
Depending on which country in which you reside, you have certain rights with respect to your Personal Information, such as you may have the right to request access to and to request the correction of your Personal Information collected by us. You may also have the right to request removal of unwanted data that you publicly post on our Sites and through our Services. Where such rights are required by applicable law, if you would like to make such a request, please contact us. See the Contact Information below.
After verifying you and your request, we will respond to your request in the manner we are legally required to do, but please be aware that the data may not be completely or comprehensively removed from our systems.
Depending on the country in which you reside, you may have additional rights. See the sections regarding various countries below for more information. If the country in which you reside is not among these sections, we will still comply with your request in accordance with our policies, but at a minimum, to the extent required by applicable law.
9. Location and International Transfer of Personal Data
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.
If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, transferring, processing and storing your Personal Information out of the country in which you reside.
10. Data Security
We have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard information that can individually identify you.
The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Sites or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given up those details and/or permitted access through those accounts. If your email account is compromised, it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised, you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, or hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites or used with our Services.
11. Data Retention
We take reasonable steps to ensure that your Personal Information is only processed for the minimum period necessary in connection with: (i) the purposes set out in this Privacy Notice; (ii) any additional purposes notified to you at or before the time of collection of the relevant Personal Information or commencement of the relevant processing; or, (iii) as required or permitted by applicable law; and thereafter, for the duration of any applicable limitation period. In short, once your Personal Information is no longer required, we will destroy or delete it in a secure manner.
We will retain your Personal Information for as long as your account is active, or as long as you are a member or account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of that Personal Information, the potential risk of harm from an unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve these purposes through other means, and the applicable legal requirements.
12. Business Transfers and Corporate Changes
You consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer and/or license (whether by contract, merger or operation of law) as part of a Transfer of any or all of our rights, in whole or in part, to your Personal Information and other information and your consents, with or without notice to you and without your further consent.
13. Children’s Privacy
Our Sites are general audience sites not directed at children under the age of 18. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 18, we will promptly delete that information.
14. Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to our Sites, Services or other services, etc., on a third-party website or network), you consent to our using the email address to send you service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Service, the Sites and/or the Mobile App to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements or offers. You may not opt out of Service-related emails.
You can add, update or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.
If you are unhappy or have concerns about the way in which we have handled your Personal Information, please contact us (see “Contact Information” below) so that we can try to resolve the issues. We encourage you to get in touch with us first; however, you also have the right to lodge a complaint with the applicable supervisory authority.
16. Third-Party Websites and Content
The website and services may contain links to other websites ("Third-Party Websites") as well as articles, photographs, text, graphics, pictures, designs, music, sound, video, information, applications, software and other content or items belonging to or originating from third parties ("Third-Party Content"). Such Third-Party Websites and Third-Party Content are not monitored or checked for accuracy, appropriateness or completeness by us, and we are not responsible for any Third-Party Websites or Third-Party Content. Inclusion of, linking to, or permitting the use or installation of any Third-Party Websites or any Third-Party Content does not imply approval or endorsement thereof by us. If you decide to leave the website or Services and access the Third-Party Websites or to use or install any Third-Party Content, you do so at your own risk. You should review the applicable terms and policies, including privacy and data gathering practices, of any website to which you navigate from the website or services.
17. Contact Information
NOTICES TO RESIDENTS OF VARIOUS NON-U.S. COUNTRIES
For the sections below starting with “Notice to Residents of”, the notices and statements pertain only to residents or citizens of that country or region, and not to any other country.
18. Notice to Residents of the U.K. and European Union
For residents of the United Kingdom or the European Union, “Personal Information” means any information relating to an identified or identifiable natural person (referred to “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We process Personal Information only when we have a legal basis to do so. The legal basis we will rely on will be one of the following:
- You have consented to the processing of your Personal Information.
- The processing is necessary to perform a contract with you or fulfill a request you have made.
- The processing is necessary to comply with a legal obligation that applies to us.
- The processing is necessary for purposes that are in our legitimate interests, such as protecting the security of our Sites, improving the functioning of our Sites and providing you with information about products in which you have expressed interest.
If we need to process your Personal Information to fulfill or enter into a contract with you, failure to provide that Personal Information will mean that we cannot perform or enter into a contract with you.
If we intend to use Personal Information that we have collected for one purpose for processing related to a different purpose, we will provide you with information about this secondary purpose and any additional information necessary to ensure fair and transparent processing before we engage in further processing.
If you are located in the United Kingdom or the European Union, you have certain rights regarding the Personal Information that we maintain about you, which in certain circumstances you will be able to exercise. The rights are as follows:
- Access. You may request a copy of the Personal Information that we maintain about you.
- Portability. If we maintain your information based on your consent or so that we could enter into a contract with you, you have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform fulfillment of member benefits with you. We will give you your Personal Information in a structured, commonly-used and machine-readable format.
- Correction. If your Personal Information is incorrect, you may request that we correct, amend or delete Personal Information that is inaccurate or incomplete.
- Deletion; Restrict Processing. You may request that we erase or restrict the processing of your Personal Information.
- Object to Processing. You may object to the processing of your personal data in certain circumstances when we process your data for the purposes of our legitimate interests.
- Right to Complain. You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of Personal Information relating to you infringes upon your rights.
- Withdraw Consent. If we are processing your Personal Information based on your consent to do so, you may withdraw that consent at any time.
Some of these rights can be exercised online via your account. For example, you can review, modify and delete certain information relating to your use of our Sites and unsubscribe to email messages. If you are unable to manage your request via your online account, then please contact us at email@example.com.
19. Notice to Residents of Australia
For residents of Australia, “Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. We may disclose your Personal Information to third parties based outside of Australia (i.e., overseas), primarily in the United States, as our service providers are located primarily outside of Australia, including our technology and internet service providers, data storage providers and digital mail providers who send communications on our behalf. However, we do not share your Personal Information with third parties for those third parties’ direct marketing purposes.
You agree and acknowledge that the overseas recipients will be subject to the privacy law of their local jurisdiction and may not be subject to any privacy obligations or to any principles similar to the Australian Privacy Principles. They will also be subject to a foreign law that could compel the disclosure of Personal Information to a third party, such as an overseas authority. Unless you notify us in writing to the contrary, you will be taken to have consented to the disclosure by us of Personal Information to overseas recipients.
You have the option to remain anonymous when dealing with us, or not to disclose certain Personal Information to us. However, this may mean that we may be prevented from being able to provide our services to you.
20. Notice to Residents of Hong Kong, China
For residents of Hong Kong, China, “Personal Information” (referred to as “Personal Data” in the Hong Kong statute definition) means information which relates to a living individual and can be used to identify that individual. It must also exist in a form which access to or processing of is practicable. The “Data Subject” is the individual who is the subject of the Personal Information.
We intend to use your Personal Information for the following direct marketing purposes:
- To communicate with you about our and our affiliates’ products and services
- To send you further notices, promotions or other marketing materials regarding our Sites and Services, our products and services, and our affiliates’ products and services.
However, we cannot use your Personal Information for such purposes without your consent. Your consent for this purpose will be requested at the time of your submission of Personal Information (e.g., at account creation, event registration, etc.) to us.
Should you want to communicate your consent to such use of your Personal Information, please contact us. See the Contact Information section above.
21. Notice to Residents of India
For residents of India, “Personal Information” means any information that relates to a natural person, which either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.
22. Notice to Residents of New Zealand
For residents of New Zealand, “Personal Information” means information about an identifiable individual.
23. Notice to Residents of Singapore
For residents of Singapore, “Personal Information” means data, whether true or not, about an individual who can be identified (a) from that data, or (b) from that data and other information to which the organization has or is likely to have access.
How We Use Your Information
Cross Border Transfer of Data
The persons or companies to whom we disclose and transfer your Personal Information may be located outside of Singapore. We shall ensure that the recipients of the transferred Personal Information are able to provide the transferred Personal Information a standard of protection that is comparable to the standards of protection set forth under the PDPA through the use of binding corporate rules (for transfers to our affiliates and other entities related to us) and written data transfer agreements (for transfers to third parties).
Singapore Data Protection Officer