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Privacy policy ATA Updated May, 22nd 2018 We respect privacy and your rights to control your personal data. Our principle guidelines are simple. We will be clear about the data we collect and why. Your data is sacredly protected by us. We do not and will not sell your data to third parties. The prime purpose of collecting your data is to improve our service as we want to serve you in the best possible manner. This Privacy Statement (the 'Statement') explains the personal information we collect from you, either directly or indirectly, and how we will use it. Personal information is any information that can be used to identify you or that we can link to you. The Statement also elaborates on the choices you can make about the data we collect, and how you can control these decisions. It applies to all services and events offered and/or organized by ATA ('ATA Services'). It also applies to any ATA-controlled website, as well as other offline interactions, such as visiting the ATA Annual Conference or attending at an event where ATA is also represented (collectively referred to as 'Services'). Please read this Statement carefully to understand how ATA may collect, use and share your personal information. The terms 'we', 'us', ‘Animal Transportation Association’ or 'ATA' are each intended as reference to ATA. The Types of Personal Information We Collect Information you provide to us We collect information you voluntarily provide to us, such as your name, address, phone number and e-mail address; for instance, when you want to learn more about ATA Products and Services or when you contact our organization for assistance related to our activities. Information we collect automatically We automatically collect information about you, such as functional data and additional usage data this regards your use of our services or information collected by cookies and similar technologies when you use, access or interact with us via our websites or app. We may, for example, collect information about the type of device you use to access our websites, the operating system and version, your IP address, your general geographic location, as indicated by your IP address, your browser type, the webpages you view on our websites, whether you interact with content available on our websites and how. Information obtained from other sources We may receive information about you from other sources, including third parties, such as partners with whom we offer co-branded services or engage in jointmarketing activities. We may also receive information about you from social media platforms, for instance, when you interact with us on those platforms. We protect data obtained from third parties according to the practices described in this Statement and we also apply any additional restrictions imposed by the source of data. Information of children ATA does not target and is not intended to attract children under the age of sixteen. Although visitors of all ages may navigate through our websites or use our app and social media, we do not knowingly collect or request personal information from those under the age of sixteen without parental consent. If, following a notification from a parent, guardian or discovery by other means, a child under sixteen has been improperly registered on our site by using false information, we will cancel the child's account and delete the child's personal information from our records. Membership Interactions with ATA To make the information in this Statement easy to understand, we have highlighted different occasions when ATA could potentially collect personal information from members. The membership interactions with ATA are broken down into the following segments: Learning about ATA As you gather more information about ATA, you may virtually or physically visit a site that we own. Examples include browsing our website, calling our staff members, Executive Officer or Board Members, physically visiting an ATA-owned premise or attending ATA-sponsored or ATA-organized events. To learn more about ATA services, you may voluntarily provide personal information, such as your name and email address during these interactions. We may also collect information about you online via cookies or similar technologies when you visit our websites. We collect: name, first-name, address, e-mail address, telephone number, IP address, and information provided by cookies or similar technology. Why: We use this information to share news about events and products offered by ATA or to respond to your own request. Additionally, the IP address helps us to understand geographic information about our website visitors better, so that we can improve our website for everyone. It is our legitimate interest to process your personal data for these purposes. Buying, ordering or consulting ATA Services & Products Once you have decided to use an ATA Service or to become a member, we offer a way for customers to order or subscribe to our organization directly through our websites, via e-mail, fax or messaging service, or over the phone or personal talk. When you apply with us, you may be asked to provide information so that we can complete your application. We collect: your name, address, phone & fax number, e-mail address, delivery/shipping address, and payment information. Why: We use this information to complete your membership, carry out any follow up with you about your application, help with any issues, and other issues related to the order of ATA Services. Processing your personal data for this purpose is necessary for the performance of the agreement we have with you. Please note, we do not store any payment or credit card information. We only use payment information in connection with the order of ATA Services and payment thereof. ATA-Services at the order of third parties From time to time, it might happen that third parties (f.e. an existing ATA member or partner) do share your data with us if related to services we provide and where you are involved as a third party. These data can reach us via e-mail, fax or messaging service, or over the phone or personal talk. The data is related to our normal activities and is required to perform our professional tasks. We collect: your name, address, phone & fax number, e-mail address, delivery/shipping address, and payment information. Why: We use this information to complete the application, carry out any follow up with you about your application or participation, help with any issues, and other issues related to the order of ATA Services. Processing your personal data for this purpose is necessary for the performance of the agreement we have with you or with a third party. Please note, we do not store any payment or credit card information. We only use payment information in connection with the order of ATA Services and payment thereof. How We Use Personal Information ATA uses the data we collect to carry out the applications we get and to provide the Services we offer. This processing is necessary for the performance of the agreement we have with you (or with a third party but in which you are involved), as well as to serve our legitimate interest. We also use the data to communicate with you, for example, informing you about your account, new products or services available, security and other types of updates. We use data to provide, operate, support and improve the ATA Services we offer. This processing is necessary for the performance of the agreement we have with you. We use data to respond to customer and member enquiries, diagnose Service problems and provide other customer care and support services. This processing is necessary for the performance of the agreement we have with you, as well as to serve our legitimate interest. We continually use data for research purposes and to develop and improve our ATA Products and Services. This processing is necessary to serve our legitimate interest. We use data to protect the security and safety of our services and our members, to detect and prevent fraud, to resolve disputes and enforce our agreements. This processing is necessary to serve our legitimate interest. We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest. We use the data we collect to deliver and personalize our communications with you. For example, we may contact you by e-mail, messaging service or other means of electronic communication (including through the ATA app) to inform you about new ATA Products or Services, security or software updates, update you on a support issue, invite you to take part in a survey or an event. This processing is necessary to serve our legitimate interest. We also use cookies and similar technologies to provide the most relevant ATA advertising to you. For information about managing email subscriptions and promotional communications, please visit ‘Your Rights and Choices’ below. How We May Share Personal Information ATA does not and will not sell personal information about our customers nor other contacts. We only disclose your data as described in this Statement. We may share information with the following types of third parties. Third Party Vendors and Partners ATA uses a variety of partners like airlines, freight forwarders, customs agencies, road trucking companies, hotels, etc. to carry out services, and also including credit card processing and e-mail communications. We only share your personal data as necessary. To complete a transaction, provide a Product or Service you have requested or authorized and only with vendors or agents working on our behalf for the purposes described in this Statement. In this case, your personal information will be shared with these agents or contractors but only for the purpose of performing services on behalf of ATA and in accordance with this Statement. It is our legitimate interest to process your personal data for these purposes. For questions about thirdparty vendors, please send an email to info@animaltransportationassociation.org. ATA-controlled affiliates and subsidiaries We share information with ATA-controlled affiliates and subsidiaries for business purposes, such as, internal administration, promoting ATA Services and providing customers with our ATA Products and Services. It is our legitimate interest to process your personal data for these purposes. Compelled Disclosure When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, veterinary authorities, investigative organizations, our affiliates or in legal proceedings. Sale or Merger We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. Of course, we shall notify you via email and/or a prominent notice on our website and inform you of your rights. The Legal Bases for Using Personal Information There are different legal bases that we rely on to use your personal information, namely: Performance of a contract The use of your personal information may be necessary to perform the agreement you have with us. For example, to complete your booking of an ATA Service, to arrange the shipment of your horse and affiliated services, to register and maintain your account, to help with shipping issues, to handle returns, or to respond to your requests. Legitimate interests We may use your personal information for our legitimate interests. For example, we rely on our legitimate interest to analyse and improve our ATA Services and the content on our websites, social media and app, to send you notifications about updates or information about ATA Services or to use your personal information for administrative, fraud detection or legal purposes. Where we process your personal information based on our legitimate interest and no opt-out mechanism is available to you, you may exercise your right to object by sending an e-mail to info@animaltransportationassociation.org. Security, Storage and Retention of Personal Information We Collect Security ATA is committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable. While no service is completely secure, ATA takes precautionary measures to help prevent information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. For example, we store the personal data you provide on computer systems that have limited access and that are in controlled facilities. We also ensure that our third-party data centre vendors provide adequate security measures. Please notify us immediately if you believe your data have been misused. If you have any questions about the security of your personal information, you can contact us at info@animaltransportationassociation.org. Storage Personal data collected by ATA may be stored and processed in our own region, in the European Union (for example, in major data centres by subcontractors), or in any other country where ATA or its affiliates, subsidiaries or service providers are located or maintain facilities. ATA and her subcontractors have put in place adequate mechanisms to protect personal information when it is transferred internationally, for example by using the Standard Contractual Clauses as approved by the European Commission. Retention ATA will retain your personal information for as long as we deem it necessary to enable you to use the website, to provide services to you, to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All personal information we retain will be subject to this Privacy Statement and our internal retention guidelines. If you have a question about a specific retention period for certain types of personal information we process about you, please send an email to info@animaltransportationassociation.org. Your Rights and Choices Your Rights We want you to be in control of how your personal information is used by us. Subject to local law, you can do this in the following ways: • you can ask us for a copy of the personal information we hold about you; • you can inform us of any changes to your personal information, or if you want us to correct any of the personal information we hold about you; • in certain situations, you can ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and • in certain situations, you can also ask us to send the personal information you have given us to a third party. Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest or the public interest, you have the right to object at any time to that use of your personal information. We rely on you to ensure that your personal information is complete, accurate and up to date. Please do inform us promptly of any changes to or inaccuracies in your personal information by contacting info@animaltransportationassociation.org. We will respond to your request as soon as possible but certainly within 30 days. For more information about how you can control the collection and use of additional usage data and Communication, Marketing and Advertising Preferences, please visit the “Your Choices sections below. We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal information. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to file a complaint with the data protection authority in your country (if one exists in your country) or supervisory authority. Your Choices ATA Account, ATA Website and ATA App If you wish to access, edit or remove profile information, change your password (where applicable), close your account or membeship or request deletion of your personal data, you can do so by sending an email to info@animaltransportationassociation.org. We will respond to any request to access or delete your personal data as soon as possible, certainly within 30 days. Your Communication, Marketing and Advertising Preferences You can opt out of receiving direct marketing communications from ATA by following the instructions included in every email sent to you via the “Unsubscribe” tab. You can also opt out of e-mail subscriptions or in-app messaging by updating your Profile and Contact Options. We respect your choice, and we will stop sending you promotional e-mails once you unsubscribe. Please do send an e-mail to info@animaltransportationassociation.org. Please note, regardless of your communication settings, we will continue to communicate with you regarding changes to terms and conditions, policy updates, routine customer service messages such as information about current or past orders, registrations or applications. Our Use of Cookies and Other Similar Technologies We use cookies and similar technologies like pixels, tags, web beacons, and other identifiers to help us personalize our website for you, remember your preferences, understand how users are using our website or app, and help customize our marketing offerings. Cookies A cookie is a small data file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. The length of time a cookie will stay on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. ATA uses both types of cookies. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted. We use the following types of cookies on our website. • Strictly necessary cookies. These cookies are essential for you to browse our website and use its features. Without these cookies, services like shopping baskets cannot be provided. • Performance cookies. These cookies collect information about how you use our websites. This data may be used to help optimize our website and make it easier for you to navigate. • Functional cookies. These cookies allow our websites to remember choices you make while browsing and personalize your experience. We may store your geographic location in a cookie for instance, to ensure that we show you the website relevant to your area. • Third Party cookies. Third party cookies are those placed by websites and/or parties other than ATA. These cookies may be used on our website to improve our products or services or to help us provide more relevant advertising. These cookies are subject to the respective privacy policies for these external services, for example, Facebook Data Use Policy or LinkedIn • Analytics cookies. We use analytics cookies, like those offered by Google Analytics, to help us understand things like how long a visitor stays on our website, what pages they find most useful, and how they arrived at ATA. To learn more about Google Analytics and your data, visit this Google webpage. How to control Cookie settings Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impair your overall user experience, as it will no longer be personalized to you. Some browsers offer a “Do Not Track” (“DNT”) signal where you can indicate your preference regarding tracking and cross-site tracking. Although we do not currently employ technology that recognizes DNT signals, we will only process your personal data in accordance with this Statement. Below you can learn about how to control cookie settings on popular web browsers: • Google Chrome • Internet explorer • Safari • Firefox Pixels In addition to cookies, we sometimes use small graphic images known as 'pixels' (also known as web beacons, clear GIFs, or pixel tags). We use pixels in our email communications to you (if you have selected to receive such communications) to help us to understand whether our email communication has been viewed. We also use third party pixels (such as those from Google, Facebook, and other advertising networks) to help us provide advertising that is relevant to your interests. Learn more about our advertising and marketing activities below. Other Identifiers When you use our app, we collect a unique ad-tracking identifier from your device (the Advertising Identifier or “IDFA” on iOS devices and the Google Ad ID or “AID” on Android devices) so that we can learn more about users of our app and provide the most relevant messaging and marketing. Although these identifiers are unique to your device, they do not contain any of your personal information such as your name or email address. How to control Identifier Settings You can control how these identifiers are used, including the ability to reset them, through your device settings. Below you can learn about how to control cookie settings on popular web browsers: • Apple iOS • Android Advertising and Modern Marketing Tools To help more people getting to know our company, we use several modern marketing tools in support of our advertising efforts. ATA may work with third-party advertisers that use cookies and similar technologies to provide more relevant advertising about ATA Products and Services on our websites and across the internet. To provide this “interest-based advertising”, parties combine non-personal data about your online activities over time which helps cater advertising that we deliver to you. Examples of this may include an ATA advertisement on a Facebook page, or a Google owned page such as a search results page or YouTube, or on a site within Google’s advertising network. We do not share your personal information as part of this process. Where necessary, we obtain your consent for this process. At all times, you can opt out of these personalized ads from third-party advertisers and ad networks. How to Contact Us If you have any questions about the use of your personal information, please email info@animaltransportationassociation.org. Unless otherwise stated, ATA is a data controller for personal data we collect through the ATA communication channels subject to this Privacy Statement. Our address is 20431 Cherrystone Place, Ashburn, VA 20147, USA. We can be contacted via email at info@animaltransportationassociation.org or by phone: +1 202 676 7077. Changes to Our Privacy Statement ATA may modify or update this Statement when necessary, to reflect membership & customer feedback and changes in our ATA Products and Services. Please review it regularly. When we update this Statement, we will revise the 'Last Update' date at the top of the Statement. If there are material changes to the Statement or in how ATA uses your personal data, we will inform you either by posting a notice of such changes, prior to them taking place, or by directly sending you a notification. We encourage you to regularly review this Statement to learn more how ATA is using and protecting your information. FAQ The following are basic questions you may have about our privacy statement. We recommend that you read the detailed statement above for additional details. Why is ATA updating its privacy statement? We now meet the high standards required by the European Union's General Data Protection Regulation (GDPR) and have updated our privacy statement to reflect that. We also strive to simplify language and remove jargon, to make our privacy statement easier to read and understand. What is the GDPR? The GDPR is a regulation intended to strengthen and unify data protection for everyone within the European Union (EU). As we believe that all our customers can benefit from its mandates, we're implementing it globally. The GDPR requires greater openness and transparency from companies on how they collect, store and use personal data, while also imposing tighter limits on the use of personal data. You can learn more here. How often do you anticipate updating your privacy statement? We will update our privacy statement as necessary to ensure that our policies are in line with international regulations, our product & services and business practices. What information does ATA collect about me? ATA collects your name, address, phone & fax number, e-mail address, payment information, location data, IP address, social identifiers, data provided by cookies and other similar technologies, functional data such as registration and system data, as well as additional usage data, for instance, performance and activity information. Why does ATA need my information? ATA uses data to provide you with the best possible services, which includes using data to improve and personalize your experiences. We also use data to communicate with you, for example, informing you about your account, new products or services available, security and other types of updates. How is my information used? ATA uses data for the following purposes: • To perform the services we provide and which you agree with by becoming a member • Future Product & Service Development • Customer / Membership Support • Security, Safety, and Dispute Resolution • Product Performance Analysis • Communication and Marketing Does ATA sell information to third parties? No. We never have. And we never will. Can I opt out of sharing my information with ATA? Yes, you can opt out of submitting certain types of personal information to ATA, for instance, additional usage data such as performance and activity information. Certain types of data that we collect are a necessity in order for ATA to perform its basic functions and tasks in a secure way and you will not be able to opt out from this data collection, sharing and/or processing ('Functional Data'). How do I delete my personal data from ATA and what are the consequences? You can always send us an email via info@animaltransportationassociation.org and request that your data be deleted. How long does ATA keep my information? ATA retains personal data for as long as necessary to provide Services, support your orders / membership and fulfil transactions you have requested, or for other essential purposes such as complying with our legal obligations, and resolving disputes and enforcing our agreements. Because these needs can vary for different data types in the context of different Products or Services, actual retention periods can vary significantly. How is information stored and secured on ATA’ servers? ATA is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. Any data we transmit over the internet is protected using encryption. The servers and technologies which are being used do belong to third parties who are also GDPR compliant. Is ATA using cookies or pixels to gather information? We use cookies and other similar technologies like pixels, tags and web beacons when you visit our website or use our App. By visiting our website or using our app, you agree to the use of cookies and similar technologies for the purposes described in our privacy statement. This helps us to provide you with the best experience and allows certain parts of our website to function properly. You can always adjust your browser or device settings to not accept cookies and similar technologies if this concerns you. Does ATA use interest-based advertising? Yes. We work with third-party advertisers that utilize cookies and similar technologies to provide more relevant advertising about ATA on our website and across the internet. To provide interest-based advertising, advertisers combine non-personal data obtained about your online activities over time to customize the advertising delivered to you. We do not share your personal information to do this. What safeguards are in place for children who have access to ATA products? ATA does not target and is not intended to attract children. ATA does not knowingly solicit personal information from children or send them requests for personal information. Although visitors of all ages may navigate through our website, we do not intentionally collect personal information from those under the age of sixteen. If, following a notification by a parent or guardian, or discovery by other means, a child under sixteen has been improperly registered on this site by using false information, we will cancel the child's account and delete the child's personal information from our records. How can I contact ATA if I have questions regarding ATA' privacy statement? If you have any questions about the use of your personal information, please send us an email to info@animaltransportationassociation.org