Last Updated May 1, 2018
This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below.
The categories of Personal Data we may collect about you are:
We also process aggregated data, which is data derived from your Personal Data for statistical purposes. Aggregated data is not considered Personal Data because it does not directly or indirectly reveal your identity. We are not required to maintain, acquire, or possess information to identify you in all circumstances. This Privacy Notice does not restrict our collection and processing of aggregated data. However, if we combine or connect aggregated data with your Personal Data so it can directly or indirectly identify you, we treat the combined data as Personal Data, which will only be processed in accordance with this Privacy Notice.
Data We Do Not Collect. We do not collect any Special Categories of Personal Data (as defined by the GDPR) about you (i.e., details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
Neither our website, nor any of the products or services we provide, are intended for anyone under the age of 16. We do not knowingly collect or process Personal Data of children under age 16. If you are under age 16, do not provide any information about yourself to us. If we learn we possess Personal Data from a child under age 16 without verification of parental consent, we will delete that data. If you believe we possess Personal Data of anyone under age 16, please contact us as set forth in Section 11 below.
Personal Information. We may collect Personal Information in a variety of ways, including:
The information we collect automatically helps us improve our websites, and deliver a better and more personalized service by enabling us to:
The technology we use for automatic data collection may include cookies. Cookies are small data files stored by a website on your computer hard drive or mobile device. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our websites; and (2) third party cookies, which are served by service providers on our websites, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Our services use the following types of cookies for the purposes set below:
|Type of Cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our websites and to enable you to use some features. For example, they help the content of the pages you request load quickly by distributing the workload. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our websites to remember choices you make when you use our websites, such as remembering your name and email address. One of the primary purposes of cookies is to provide a convenience feature to save you time. Functionality cookies tell the Web server that you returned to a specific page. For example, if you register for a webinar on our websites, a cookie helps us to recall your specific information on subsequent visits. When you return to the same website, the information you previously provided can be retrieved, so you can easily use the customized features.|
|Analytics and Performance Cookies||These cookies collect information about your use of the websites, and enables us to improve them. For example, analytics cookies show us which are the most frequently visited pages on the websites, help us record any difficulties you have with the websites, and show us whether our advertising is effective. This allows us to see the overall patterns of usage on the websites, rather than the usage of a single person. We use the information to analyze the website traffic, not to examine individually identifying information.|
For our website analytics, we use Google Analytics. Google Analytics uses its own cookies. It is only used to improve how our services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can disable Google Analytics by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
|Advertising Cookies||Advertising cookies are set to display targeted promotions or advertisements based upon your interests on the website or to manage our advertising. These cookies, collect information about your activities on this and other sites to provide you targeted advertising. Advertisements are not shown for website visitors outside of the United States.|
For advertising cookies, we use DoubleClick by Google (Ad Platform). You can read more about how Google protects your data here: https://www.google.com/policies/privacy/
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.|
We may process Personal Information:
We may provide your Personal Data to the following third-parties:
Taking into account the state of the art, costs of implementation, nature, scope, context and purpose(s) of processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. Unfortunately, the transmission of information via the internet is not completely secure, but we do our best to protect your Personal Data.
We will retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it; including to satisfy 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 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.
In some instances, you may ask us to delete your Personal Data. For more information, see Request Erasure of your Personal Data below for further information.
In some instances, we may anonymize your Personal Data (so it can no longer be associated with you) for research or statistical purposes; in which case, we may use this information indefinitely without further notice to you.
You have certain rights with respect to your Personal Data under the General Data Protection Regulation (GDPR). Please click on the links below to find out more about these rights:
How to exercise your rights:
You can always Contact Us to exercise your legal rights.
Usually, There Is No Fee Required To Exercise Your Personal Data Rights. You will not have to pay a fee to excise your rights, nor is the purchase of products or services a condition for you to exercise your rights. You are also entitled to receive a copy of your Personal Data undergoing processing. However, if in exercising your rights, your request is unfounded, repetitive or excessive, we may charge reasonable fees taking into account the administrative costs of providing the information or taking the requested action. We may also refuse to act on the request. If you request more than one copy of your Personal Data, we may also charge you reasonable fees based on our administrative costs to provide you copies.
What We May Need From You. When we have reasonable doubts concerning the identity of an individual making a request to exercise his/her rights, we may request additional information necessary for us to confirm the requestor’s identity.
Our Response. Within one month of receiving a request to exercise your rights, we will perform the requested action and/or acknowledge your request. If, based on the complexity and number of your requests or if we require additional time to verify the accuracy of your Personal Data, we require more than one month to perform the requested action, we will inform you that we require additional time and provide the reasons additional time is necessary. If your request to us is by electronic means, we will respond by electronic means, unless you request that we respond in a different manner.
If we refuse to perform any requested action because doing so would be inconsistent with applicable law, this Privacy Notice, or for any other reason, we will provide you an explanation for our refusal.
Our websites may include links to third-party websites, plug-ins and applications, such as “share” or “like” buttons. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control third-party websites and are not responsible for their privacy practices. If you would like to know about a particular website’s practice, we encourage you to read their privacy notice.
YOUR LEGAL RIGHTS
You have the Legal Right to:
Request access to your Personal Data. This enables you to be informed whether we are processing your Personal Data, and if we are, receive access to the Personal Data and the following information: (i) the purpose of the processing; (ii) the Personal Data categories; (iii) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed – in particular, recipients in third countries or international organizations; (iv) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (v) the existence of the right to request from us rectification or erasure of Personal Data or restriction of processing of Personal Data concerning you or to object to such processing; (vi) the right to lodge a complaint with a supervisory authority; (vii) where your Personal Data is not collected from you, any available information as to the source of your Personal Data; and (viii) the existence of automated decision-making, including profiling, referred to in GDPR Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
Request erasure of your Personal Data. This enables you to ask us to erase Personal Data when : (i) processing the Personal Data is no longer needed for the purposes for which it was collected or otherwise processed; (ii) the Personal Data was obtained based on consent, and we possess no other legal ground for processing; (iii) the Personal Data was processed based on our legitimate interests, and there are no overriding legitimate grounds for processing; (iv) the Personal Data is processed for direct marketing purposes; (v) the Personal Data has been unlawfully processed; or (vi) the Personal Data must be erased to comply with our legal obligation. Note, however, we may not be able to comply with your request of erasure for specific legal reasons, which reasons will be communicated to you, if applicable, in response to your request.
Object to processing of your Personal Data. This enables you to object to the 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 situation that makes you feel the processing impacts 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 Personal Data which override your interests, 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 if: (i) you want us to establish your Personal Data’s accuracy; (ii) our processing of your Personal Data is unlawful but you do not want us to erase it; (iii) you need us to hold Personal Data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you objected to our processing of your Personal Data but we need to verify whether we have overriding legitimate grounds to process the same.
Request the transfer of your Personal Data. We will provide you, or a third party you chose, your Personal Data in a structured, commonly used, machine-readable format. Note this right only applies to automated information you initially provided consent for us to process or where we used your Personal Data to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Data. This enables you to withdraw your consent to process your Personal Data. However, your withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.
We are the controller and are responsible for your Personal Data that we process. If you have any questions about this Privacy Notice, including any requests to exercise Your Legal Rights, please contact us at:
150 N Michigan Avenue, Suite 1580, Chicago, IL 60601
Provided we can confirm your identity, we will also provide information regarding your rights over the phone if you contact us at 312-878-6600.
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