1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:
|GDPR||General Data Protection Regulation, European Parliament and Council of European Union (2016) Regulation (EU) 2016/679|
|CCPA||TITLE 1.81.5. California Consumer Privacy Act of 2018 Ca. Civ. Code Div. 3, Pt. 4, Tit. 1.81.5.|
|Colorado Data Privacy Act||Colorado Data Privacy Act, Colorado Revised Statutes §§6-1-713 et. seq.|
|Personal Information:||Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual or identifiable natural person.|
|Products and/or Services||Any Products or Services that we may promote on our Site.|
|Site||Our website: www.nationalwesterncenter.com.|
|Special category personal information:
|· Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
· Genetic and biometric data
· Data concerning health, sex life or sexual orientation
|We, Us, Our:||National Western Center Authority, a Colorado nonprofit corporation (doing business as the National Western Center).|
2. Personal Information We Collect About You. We collect the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
|Categories of Personal Information||Specific Types of Personal Information Collected|
We also collect email and name information from visitors that sign up for an email newsletter on our Site.
We also post web links on our Site which users may click to go to a third party website to register for events related to the National Western Center. Users that wish to register using those third party websites will submit their name and other identifying information like address, phone number and email.
|Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)||We track Site visitor traffic using Google Analytics to help us optimize our Site’s functionality and information.|
|Geolocation data||We track Site visitor traffic using Google Analytics to help us optimize our Site’s functionality and information and Google Analytics provides geolocation data of Site traffic.|
Additionally, we do not collect “Personal Identifying Information” as defined in the Colorado Data Privacy Act, meaning: social security numbers; personal identification numbers; passwords; pass codes; official state or government-issued driver’s license or identification card numbers; government passport numbers; biometric data, employer, student, or military identification numbers, or a financial transaction device (i.e. a credit, debit or atm card).
3. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide Services on our Site and at the National Western Center that are relevant to you||For our legitimate interests or those of a third party, i.e. to provide events and Services to you at the National Western Center campus.|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Statistical analysis to help us manage our business, e.g. in relation to our visitor and customer base, event and food offerings or other efficiency measures.||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorized access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Marketing our Services and events, and those of our partners, vendors and event promotors and other selected third parties to:
—existing and former customers;
—third parties who have previously expressed an interest in our Services;
—third parties with whom we have had no previous dealings.
|For our legitimate interests or those of a third party, i.e. to promote our business to existing and former visitors to and customers and suppliers of the National Western Center (and its partners and vendors).|
The above table does not apply to special category personal information, which we will only process with your explicit consent.
4. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our campus, events and Services.
We have a legitimate interest in processing your personal information for promotional purposes (see above, “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell OR share it with other organizations outside the National Western Center group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
We may ask you to confirm or update your marketing preferences if you instruct us to provide further information about the National Western Center in the future, or if there are changes in the law, regulation, or the structure of our business.
5. Who We Share Your Personal Information With. We routinely share personal information with:
|Personal Information||Who We Share It With|
|Name and email information||We share this information with our email marketing service provider (Constant Contact) to send emails that promote events on campus and other information in our newsletters.|
|IP addresses, cookies, Site visitor traffic||We provide this information to Google Analytics which we use to help us monitor and analyze our website traffic information to optimize our Site.|
|Geolocation data||We provide this information to Google Analytics which we use to help us monitor and analyze our website traffic information to optimize our Site.|
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not share your personal information with any other third party.
6. Where Your Personal Information is Held. Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
As we are a nonprofit corporation based in Colorado and focused on activities and Services available on our campus located in Colorado, for purposes of the GDPR, all or most of these third parties are based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”
7. How Long Your Personal Information Will Be Kept. We will keep your personal information while we are providing any Services to you. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
8. Transferring Your Personal Information Out of the EEA. As a nonprofit corporation based in the USA that is focused on marketing our Services and Products to people in the USA, at this time we do not intend to: (i) offer Services and Products through our Site to people in the European Economic Area (“EEA”) defined by the GDPR as “EU Data Subjects,” (ii) monitor their behavior or (iii) process their Personal Information. To the extent you are an EU Data Subject, then to deliver Services information to you, it will be necessary for us to share your Personal Information outside the EEA, e.g.:
These transfers are subject to special rules under European and UK data protection law.
For example, the following countries have been assessed by the European Commission as providing an adequate level of protection for personal information: Andorra, Argentina, Canada (commercial organizations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay. This means that if we wanted to transfer your personal information to be processed in those countries we could. But we don’t intend to.
Except for the countries listed above (including the USA), other countries do not have the same data protection laws as the United Kingdom and EEA. Because we process your personal information in the USA we will ensure the processing complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses contact us at firstname.lastname@example.org. If you would like further information, please contact us (see “How To Contact Us” below).
9. Your Rights Under the GDPR. Users subject to the GDPR have the following rights under the GDPR:
|Right to Access||The right to be provided with a copy of your personal information (the right of access)|
|Right to Rectification||The right to require us to correct any mistakes in your personal information|
|Right to be Forgotten||The right to require us to delete your personal information—in certain situations|
|Right to Restriction of Processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Right to Data Portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|Right to Object||The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
|Right Not to be Subject to Automated Individual Decision-Making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the GDPR.
10. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
The GDPR also gives users subject to the GDPR the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
We may change this privacy notice from time to time – when we do, we will inform you via our website.
Our contact details are shown below:
THE NATIONAL WESTERN CENTER
4701 Marion Street, Suite 401
Denver, CO 80216
19. Do You Need Extra Help? If you would like this notice in another format please contact us (see “How to contact us” above).
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