Privacy and Cookie Policy

This Privacy and Cookie Policy (the “Policy”) sets out details about the personal information that BSRIA Inc., a Delaware corporation with an office located at 150 S Wacker Drive Street, # 2400, CHICAGO, IL 60606 (“we”, “our”, “us”, “BSRIA”), may collect, use, disclose and otherwise process about individuals who interact with us (“you”, “your”) For purposes of this Policy, "personal information" means information that identifies, relates to, describes, or could reasonably be linked to an identified or identifiable individual, subject to applicable law.

This Policy is provided for informational purposes only and does not create contractual rights or obligations. It may be amended by us from time to time, in our sole discretion. If we decide to change this Policy, we will post the amended policy on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it.

We may use your personal information for the purposes described in this Policy and for other purposes that are compatible with those purposes or as otherwise permitted by applicable law. If we make material changes to how we use personal information, we will update this Policy and provide any additional notice required by applicable law.

In terms of retention periods, we will not keep your personal information for longer than is necessary to fulfill the purposes described in this Policy, including to comply with applicable legal, regulatory, accounting, tax, and recordkeeping requirements, resolve disputes, enforce our agreements, and protect our legal rights.

Consent

Where required by applicable law, we will obtain your consent before collecting certain types of personal information. You may withdraw your consent at any time by contacting us at information@bsria.com. Your withdrawal will not affect any collect conducted before your consent was withdrawn.

Certain Rights

Depending on your state of residence and applicable U.S. privacy laws, you may have certain rights regarding the personal information we collect and process about you. If you wish to exercise any applicable privacy rights, please contact us at: information@bsria.com.

1. WEBSITE/TELEPHONE USERS

We are committed to respecting your privacy and protecting your personal information. We have structured our website [JE1] so that, in general, you can visit that part of the website which is accessible to non-members of BSRIA without identifying yourself or revealing any personal information. Once you choose to provide us with any personal information, then you can be assured that it will only be used in accordance with this Policy and applicable law.

We are committed to respecting the privacy of users entering this website and we recognize the importance of the responsible use of information collected on our website and other communication channels. We will do our best to maintain the accuracy and security of the personal information we collect. We will not sell or license your personal information as defined under applicable privacy laws unless permitted by law and subject to any required disclosures or opt-out rights.

In general, our service automatically gathers certain usage information about the numbers and frequency of visitors to our website. We only use such data in an aggregated form in our own data logs and web analytics tools such as Google Analytics. This collected data helps us to determine how much our customers use parts of the website, so we can improve website functionality, content, and user experience.

Also, we may provide aggregated statistics about our customers, sales, traffic patterns and related website information to reputable third party vendors, but these statistics will not identify individual users.

The type of personal information we collect

When you access our website, we may collect the following categories of personal information:

Login data (i.e. username and password) which you input in respect of our subscriber/membership services;
Data you input into online forms. For example, if you are signing up to download a free guide you will be asked for your contact details;
On our website we may provide space for your comments and/or provide a short survey for you to complete. This is used to help us refine the content and relevance of our website.

For information you are asked to provide (as part of signing up to a service), you are obliged to provide this to enable us to perform the contract with you and/or to ensure our IT systems remain secure and effective. A failure to provide this may mean we are unable to provide you with the services you require.

For registered users on our website, we will track and record individual’s web activity such as document downloads, orders and requests to record the level service we provide and to inform of relevant products and services.

We may use cookies and similar tracking technologies when you visit our website. Cookies are pieces of information sent to your browser on a web server and stored on your computer's hard drive for record keeping purposes. Cookies cannot be used to obtain other information from your hard disk. We use cookies to make visiting our website easier. Cookies allow us to save passwords for you so that you will not have to re-enter them the next time you visit. Cookies are also used to collect statistical information and may be used to identify individuals.

Most browsers are initially set up to accept cookies, but you can manage or disable cookies through your browser settings. If you prefer you can reset your browser either to notify you when you have received a cookie or to refuse to accept cookies. It is important to note that if you choose not to accept cookies, or you set your browser not to accept cookies, you may not be able to use certain features on our website.

Log files are also created when users visit our website. They allow us to record visitors use of our website and include your IP address. We put together log file information from all our visitors, which we use to make improvements to the content and layout of our website and to the information in it, based on the way that visitors move around it.

Your IP address is collected and recorded automatically when you access our website to assist us in monitoring and improving content and for security reasons. You are, therefore, obligated to provide this when accessing our website.

Telephone users: we may monitor, record, store and use any telephone communication with you where permitted by applicable law in order to check any instructions given to us, for training purposes and to improve the quality of our customer service.

Where required by applicable law, we will provide notice or obtain consent before recording telephone communications.

The purposes of collecting personal information

We may use the personal information we collect for the following purposes:

To register you as a new client/user and provide services to you as requested;
To be able to contact you in relation to the service and effectively manage our relationship with you;
To enable us to ensure efficiency and security of our systems (e.g. prevention of unauthorized access) and make improvements where necessary, including for user experience of our website;
To help resolve disputes arising from verbal orders by customers and to clarify details of verbal customer orders;
To make business decisions about the provision of services and our website;
To comply with applicable legal obligations, resolve disputes, and protect our legal rights.

Where you have requested information, registered for events, subscribed to updates, or otherwise provided your contact information for marketing purposes, we may use your personal information to send you communications about our products, services, and events in accordance with applicable law.

Use of personal information and applicable privacy laws

We use and disclose personal information for business and commercial purposes. Depending on where you reside, applicable privacy laws may provide you with certain rights regarding your personal information, including rights to access, delete, correct, or opt out of certain uses or disclosures of your information.

We do not rely on a single legal basis for collecting personal information, as U.S. privacy laws generally do not require the identification of a lawful basis for each collect activity. Instead, we collect, use, and disclose personal information as permitted by applicable law and as described in this Policy.

Sharing your personal information

Your personal information will be shared internally with our IT, marketing and any other relevant business departments. It may also be provided to the management at BSRIA (and their support staff and subordinates where appropriate) to the extent necessary for their role and to make decisions about the business; however, where possible and appropriate, we may use aggregated, anonymized, or de-identified information (e.g. statistics). Records of telephone calls with us may be provided to the management at BSRIA (and their support staff or subordinates where appropriate) where necessary to resolve disputes arising from verbal orders by customers and to clarify details of customer orders.

Your personal information may also be shared with our professional advisers, consultants, contractors, and service providers assisting us in connection with the matter, as well as government agencies, courts, regulators, or other third parties where required or permitted by applicable law or legal process. As a convenience to BSRIA customers, our website contains links to third party websites. Clicking on those links may allow third parties to collect your personal information in accordance with their own privacy practices. We do not have control and are not responsible for the privacy practices, content, or security of such websites and would encourage you to read the privacy notices for websites you visit.

2. CLIENTS/POTENTIAL CLIENTS

The type of personal information we collect

We may collect the following categories of personal information from clients and prospective clients:

Contact details of those instructing us (such as name, job title, address and email address) or potential clients;
In some instances, we may require documentation to verify identity including passport or driving license details for individuals or details of shareholders and directors for organizations;
Information about the matter you are instructing us on;
In the case of persons part of a BSRIA committee or network: information arising from committee/network meetings;
In some instances, we may also need to carry out credit checks or other financial checks with (and obtain personal data from) financial organizations;
Where fees are charged for a service, we will hold financial information and transaction details, including a partial amount of payment card details;
We may also need to process personal information from third parties which are necessary for the performance of the contract with you.

In certain circumstances, we may obtain additional information from third parties, including financial institutions or service providers, where permitted by applicable law, for purposes such as verifying information, assessing eligibility, preventing fraud, or managing financial transactions.

Certain information may be necessary for us to provide requested services, establish or manage a business relationship, comply with applicable legal requirements, or maintain the security and integrity of our operations. If you do not provide information that is necessary for these purposes, we may be unable to provide certain services or fulfill your requests.

The purposes of collecting personal information

We may use the personal information we collect for the following purposes:

Perform our contractual obligations (including contacting you, providing services or advice to you) or take steps to enter into a contract (e.g. provide a quotation);
Preparatory steps to deal with your enquiry to potentially engage you as a client;
Verify identity and source of funds where legally required to do so (for example, in accordance with anti-money laundering legislation);
Retain a record for the defence of legal claims or insurance purposes;
Market services to you (such as updates and event invitations) which we consider would be of interest to you;
Retain a record for the purpose of audits or audit requests from clients and for external audits/quality checks;
Keep account of fees paid or payable for services and financial information as necessary to complete transactions;
Produce and retain information and guidance from committee, network and similar meetings;
Comply with applicable legal obligations, resolve disputes, and protect our legal rights.

Depending on where you reside, applicable privacy laws may provide you with certain rights regarding your personal information, including rights to access, delete, correct, or opt out of certain uses or disclosures of your information.

Sharing your personal information

Your personal information will be shared internally to the extent necessary to carry out our obligations under our contract with you and/or in line with the purposes set out above. Contact details of committee/network members may be shared within the BSRIA committee/network to help communication between parties.

Where you are making payments to us, card payments are processed securely through our third-party payment processor and financial service provider, Sage Pay, where details are entered directly. Payment card information is handled in accordance with applicable payment card industry standards and is processed directly through Sage Pay. For online orders, we capture and hold a partial amount of your payment card details which is required for security, verification and recordkeeping purposes and is mandated by Elavon. We hold these partial card details securely with restricted access and do not hold enough data to make future transactions. If we receive written card payment details, we securely destroy this information once the payment is processed. Your personal information may also be shared with financial institutions, payment processors, and other service providers as necessary to process transactions, prevent fraud, maintain security, and administer our services.

Your contact details may also be shared with our marketing team to ensure you are invited to events and provided with updates that we believe may be of interest to you. Where required by applicable law, we will provide you with the ability to opt out of marketing communications.

We may need to share your personal information with professional advisers, consultants, contractors and other service providers we contract with such as specialist sub-contractors and accreditation bodies to obtain advice in relation to the matter you have instructed us on, as well as government agencies, courts, regulators, or other third parties where required or permitted by applicable law or legal process.

We will also share your personal information with third parties where required by law (for example to comply with anti-money laundering legislation) and where it is necessary to administer the working relationship with you (as stated above). We may also need to share personal information with third parties such as potential buyers of the business where applicable (the recipient of this information will be bound by confidentiality restrictions if the personal information cannot be anonymized).

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Policy, provide our services, maintain business records, comply with applicable legal and regulatory obligations, resolve disputes, enforce agreements, and protect our legal rights.

Once information is no longer required, we securely delete, destroy, or de-identify it in accordance with our retention policies and applicable law.

3. PROFESSIONALS AND SERVICE PROVIDERS WE ENGAGE

This may include consultants, specialist sub-contractors, accreditation bodies, ICT providers, financial services providers, marketing agencies and any other professional service providers.

The type of personal information we collect

We will collect the following categories of personal information about professional and service providers we engage or consider engaging:

• Business contact information, including your name, employer, job title, business address, telephone number, and email address;

• Information relating to the services you provide, including communications, advice, reports, work product, qualifications, and other information relevant to our engagement with you.

You are obliged to provide this necessary information to enable us to perform the contract entered into with you or to make enquiries to potentially engage your services. A failure to provide this information may mean we are unable to enter into a contract with you or continue a business relationship with you.

The purposes of collecting personal information

To ensure we can contact you and you can provide the service contracted or make enquiries to obtain said service. We also retain this personal information to ensure we have a record of services to establish/exercise/defend legal claims and to assess the provision of future services from you.

Your personal information may also be collected to comply with applicable legal obligations and protect our legal rights and the rights of our clients.

Depending on where you are established, applicable privacy laws may provide you with certain rights regarding your personal information, including rights to access, delete, correct, or opt out of certain uses or disclosures of your information.

Sharing your personal information

Your personal information will be shared internally to the extent necessary to carry out our functions under our contract with you and our client. This is likely to include sharing personal data with our client (on whose matter you are instructed), the staff members responsible for the work, their supervisor and subordinates, together with our IT, finance teams and any other relevant business departments, where appropriate.

Your personal information may also be shared with other staff at BSRIA for the purposes of considering future instructions to you, or any other professional advisers, contractors, service providers, as well as government agencies, courts, regulators, or other third parties where required or permitted by applicable law or legal process.

4. OTHER PARTIES TO A MATTER

Other parties to a matter may include government agencies, regulatory authorities, non-governmental organizations, advisory & standard committees, educational institutions, industry organizations, and other individuals or entities involved in a matter for which we provide services.

The type of personal information we collect

We may receive your personal information from our client, from you directly, or from another third party if you are involved in a matter for which we have been engaged.

The personal information we collect may include:

Your name;
The name of the organization with which you are affiliated;
Your job title or professional role;
Your business contact information, including your email address, mailing address, and telephone number;
Information you provide to us or to our client in connection with the matter, including your communications, comments, opinions, or other relevant information.

The purposes of collecting personal information

The personal information is collected to ensure we are able to contact relevant parties on a matter or to provide further information relevant to the matter in question.

It may also be collected to comply with applicable legal obligations, resolve disputes, and protect our legal rights and the rights of our clients.

Sharing your personal information

Your personal information will be shared internally to the extent necessary to carry out our contract with our client and ensure the smooth running of the matter in question. This is likely to include sharing personal information with our client, the staff member responsible for the work, their supervisor and subordinates, finance, IT, and any other relevant business departments. Your personal information may also be shared with our professional advisers, consultants, contractors, and service providers assisting us in connection with the matter.

5. MARKETING RECIPIENTS/EVENT DELEGATES

The type of personal information we collect

We may collect your personal information including your name, employer, job title, email address, and mailing address for marketing purposes.

In most cases, we will collect this personal information from you directly when you have signed up for services or events; however, we may also collect business information from publicly available sources such as your employer’s website, from accredited third party data suppliers, event organizers, or other third party sources, where permitted by applicable law.

Where fees are charged for a service, we will collect financial/billing information and transaction/payment details, including a partial amount of payment card details. Payment card information is processed through our payment service provider, and we retain only the information necessary for our business, accounting, security, and recordkeeping purposes.

You are not obliged to provide this information; however, if you do not do so we may not be able to provide the services requested (for example, to receive updates, we would need a valid email address).

You may opt out of marketing communications at any time by emailing information@bsria.com. Alternatively, each of our marketing communications contain an ‘opt out’ hyperlink so that you can opt out easily at any time. Even if you opt out of marketing communications, we may continue to send you non-promotional communications, such as those relating to your account, transactions, services you have requested, or other business communications.

Photography or video may be used at our events for promotional, educational, archival, documentation, and business purposes. You will be notified about this before or during the event. If you do not wish to be photographed or videoed, please let us know by emailing information@bsria.com. While we will make reasonable efforts to accommodate your request, we cannot guarantee that you will not appear incidentally in group photographs or recordings taken in public areas of the event.

Purposes for collecting personal information

We may collect this personal information to send you marketing updates by email (and in some cases by post) such as industry news, new services and event invitations that we believe may be of interest to you or that you have expressly requested.

If you have opted out of marketing updates, we may retain your personal information as a record of those who have opted out to ensure that we do not contact you further for these purposes.

Sharing of personal information

We will take reasonable measures to protect your personal information and share it only as described in this Policy or as otherwise permitted or required by applicable law.

Your personal information will be shared internally with relevant staff members, our marketing, IT teams and any other relevant business departments. We may use external marketing companies for marketing purposes. We use a third party email service (CommuniGator) to send out electronic communications. In respect of hard copy mailings, we may supply contact details to mailing houses in order for fulfilment – such data is not used for any other purpose and is destroyed by the mailing house following each mailing. Save for this, we do not envisage needing to share your personal information with external marketing companies and will only do so if it is necessary for particular tasks assigned to them pursuant to their role or as otherwise permitted by applicable law.

Where fees are charged for a service, our finance team and payment service provider will also have access to your personal information to the extent necessary to recover payments from you and record your payment record and financial details. Card payments are processed securely through the third party Sage Pay system where details are entered directly. For online orders, we capture and hold a partial amount of your payment card details which is required for security, verification and recordkeeping purposes and is mandated by Elavon. We hold these partial card details securely with restricted access and do not hold enough data to make future transactions. If we receive written card payment details, we securely destroy this information once the payment is processed. Your personal information may also be shared with financial institutions, payment processors, and other service providers as necessary to process transactions, prevent fraud, maintain security, and administer our services.

Where you sign up to attend our events, your name, organization, or other registration information may appear on attendee badges, sign-in sheets, attendee directories, or similar event materials that may be visible to other participants. By attending the event, you acknowledge that this information may be accessible to other attendees as part of the normal administration of the event.

6. THIRD PARTIES WE CONTACT (OR WHO CONTACT US)

The type of personal information we collect

We may collect and use your personal information including your name and contact details where you have contacted us (e.g. for information) or where we have obtained your information from a public source or third party and wish to request information. If we receive any communication from you, then we will also process any personal information contained within your request.

An example may be where you are a prospective employer and contact us for a reference or, similarly, where we seek a reference for someone we intend to employ. Another example may be where we contact you to see if you would be interested in hosting a joint event or where we seek to use your business service, vice versa, or where you market to us.

This covers a variety of requests and, in most cases, we do not envisage you being obliged to provide your personal information. However, if you choose not to provide personal information that is reasonably necessary for us to respond to your request, evaluate a business opportunity, or provide requested information or services, we may be unable to fulfill your request or communicate with you effectively.

Purposes for collecting personal information

The purpose of us processing your personal information is to allow us to respond to your request or to seek information.

Depending on where you are established or reside, applicable privacy laws may provide you with certain rights regarding your personal information, including rights to access, delete, correct, or opt out of certain uses or disclosures of your information.

Sharing of personal information

Your data will be shared internally with those parties relevant to the information request. If your request requires this, it may be shared with other external parties.

7. VISITORS TO OUR PREMISES

The type of personal information we collect

BSRIA operates CCTV systems at its premises and therefore will process images of anyone entering its premises. In locations that have CCTV, there are signs displayed notifying you that CCTV is in operation.

In addition, data logging visits to our premises will be held, and may include your name, job title, the company you work for, the purpose of your visit, who you are visiting, and the date and time of your visit, and other information reasonably necessary to manage access to our facilities and maintain the security of our premises.

Purposes for collecting personal information

The purpose of us collecting personal information captured by CCTV is to detect and observe intruders, for the detection and investigation of crime, manage security risks, reduce the risk of sabotage to BSRIA, counter fraud, theft, vandalism and other unlawful or inappropriate activity, respond to emergencies, deal with alleged harassment and to provide evidence for investigations and litigation, or as otherwise permitted or required by applicable law.

Data logged from visits to BSRIA’s premises is collected and used to manage access to our facilities, verify visitor identity, maintain visitor records, restrict access to authorized areas, protect the safety and security of our premises, comply with health and safety requirements, respond to emergencies, and maintain appropriate business and security records.

Sharing of personal information

CCTV recordings may be accessed or disclosed only to authorized personnel and, where appropriate, to our service providers, law enforcement authorities, regulators, insurers, legal advisers, or other third parties as permitted or required by applicable law, including for the purposes described above.

We will not disclose CCTV recordings for public display, promotional, or entertainment purposes unless required by law or with appropriate authorization.

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