The American Free Enterprise Action (“AFEA”) believes that the protection and privacy of your Personal Data and Non-Personal Data (collectively “Data” or “Your Data”) is paramount and we value your right to privacy. AFEA strives to protect Data that we collect through your interaction with the AFEA family of websites (“AFEA Websites”), AFEA applications (“AFEA Apps”), AFEA social media tools (“AFEA Social Media”) and other digital and non-digital spaces where AFEA may collect Data (AFEA Websites, AFEA Applications, and AFEA Social Media, and other digital and non-digital spaces, respectively, and collectively, “AFEA Digital Assets”).
Data you provide to us through your use of AFEA Digital Assets helps to inform the AFEA about how best to provide you with a fulfilling user experience as it relates to our mission. Our goal is to insure that Your Data is secure, and that AFEA only uses Your Data subject to the terms and conditions set forth below.
Data AFEA collects
YOU PROVIDE DATA TO US TO CREATE YOUR ACCOUNT OR TRANSACT BUSINESS WITH US.
We collect Data from all visitors (“Users”) to AFEA Digital Assets in order to interact with you. The following are examples of the types of Data we collect:
How AFEA uses your data
WE USE YOUR DATA TO CONTACT YOU, PROVIDE SUPPORT FOR YOUR MEMBERSHIP, CONDUCT SURVEYS, AND PERSONALIZE OUR SERVICES TO YOU.
We use Personal Data that is collected on AFEA Digital Assets in the following ways:
• To provide member related services;
• To deliver services, such as educational programs, information or newsletters you request or purchase;
• To alert you to special offers, updated information and other new services from AFEA, other third parties, or to forward promotional materials;
• To process your order and, if necessary, to contact you regarding the status of your order;
• To fulfill the terms of a promotion;
• To ensure the AFEA Digital Assets are relevant to your needs;
• To help us create and publish content most relevant to you;
• To request your feedback about your experience with AFEA;
• To allow you access to limited-entry areas of AFEA Digital Assets.
• For other business purposes that help optimize your experience as you interact with AFEA Digital Assets.
Release of data to third parties
Personal Data collected as a function of the AFEA Digital Assets will not be released to third parties except to further the purpose for which you provided the Data and in the following instances:
• To fulfill a service to you including answering questions, completing an order or to follow through on a sweepstakes entry.
• To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your Personal Data for research, administrative and/or internal business purposes. These parties may use your Personal Data to contact you with an offer or advertisement related to a product or service, or they may use such Data for their own research, administration or business purposes. If you do not want us to share your Personal Data in this manner, let us know.
• To unaffiliated third-party service providers, agents or independent contractors who help us maintain our AFEA Digital Assets and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on AFEA's behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We seek to ensure that these unaffiliated third parties will not use the Personal Data for any other purpose than to provide the administrative services for which they are responsible.
• To complete your purchase. If you choose to make a purchase on AFEA Digital Assets, we may collect from you your credit card number, billing address and other Data related to such purchase, and we may use such collected Data in order to fulfill your purchase. We may also provide such Data to unaffiliated third parties as necessary to complete your purchase (for example, to process your credit card).
• To comply with the law or in the good faith belief that such action is necessary to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of AFEA and AFEA Digital Assets or act in urgent circumstances to protect the personal safety of our end users.
• To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
• To track and analyze non-identifying and aggregate usage and volume statistical data from our Users and provide such Data to third parties.
• To protect against potential fraud, we may verify with third parties the Data collected from AFEA Digital Assets. In the course of such verification, we may receive Personal Data about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card Data and address matches the Data that you supplied to us, and that the card has not been reported as lost or stolen.
Third party websites and advertisers
Forums, chat rooms and other public posting areas
Please note that any Data you include in a message you post to any social page, chat room, forum or other public posting area is available to others. If you don't want people to know your email address, for example, don't include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY DATA IN SOCIAL PAGES, CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE DATA THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.
Opt-out of communications
We communicate with Users on a regular basis via email. For example, we will use your email address to contact you regarding membership renewal and dues payments, to confirm a request you have made of AFEA, to send you notice of upcoming payments that are due, to send you information about changes to our products and services or to send notices and other disclosures as required by law. Generally, members cannot opt-out of these communications since it is necessary to keep members of informed of specific information regarding membership and actions related thereto.
AFEA provides you the opportunity to exercise an opt-out choice if you do not want to receive other types of communications from us, such as messages or updates from us regarding new services and products offered on AFEA Digital Assets or if you do not want us to share your Personal Data with third parties. For emails, you may opt-out by clicking on the "unsubscribe” link within the text of an email. We will process your request to unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed. If you have elected to receive notices to your mobile device via text message, you may opt-out by replying “STOP” to such mobile message. You may receive a confirmatory text message in response to your “STOP” request and you hereby consent to receipt of such confirmation.
Your choices and obligations data retention
We keep your Data for as long as you are a Member or as long as your relationship with AFEA Digital Assets continues and as required by law. We retain your Data while your membership is active or as necessary to continue to provide services including fulfilling orders, accessing the Members Only section of our website, etc. This includes Data you or others provided to us and Data obtained from your use of AFEA Digital Assets. There may be some instances where we retain Non-Personal Data in a deidentified or aggregated form.
Rights to access and control your personal data
You can access, change or delete Your Data if you have a user account by logging into your member account. You can also email us at firstname.lastname@example.org.
We collect Your Data in many ways, most often where you provide it to us, and we provide you with several options for collecting, using and sharing of Your Data, including deleting or correcting Data you have provided to us. We offer you settings to control and manage Your Data through your member account.
For personal data that we have about you:
• Delete Data: You can ask us to erase or delete all or some of Your Data (for example if you resign from being a member) and we will work hard to honor all requests in a timely manner. In some instances, we may not be able to delete your Personal Data in order to comply with applicable laws (for example, it is necessary to keep the financial records of a transaction with you).
• Change or Correct Data: You can edit some of Your Data through your member account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of Your Data.
• Right to Access and/or Take Your Data: You have the right to see Your Data and take your data and we will work with you to be sure we can provide the most complete set of Your Data and a secure way to transfer Your Data.
• Resignation/Account Closure: We will keep some of Your Data even after you resign your membership with AFEA or close your member account in order to fulfill any final service requests. Please note that we will retain Your Data even after you have resigned your membership or closed your member account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain deidentified Data after your account has been closed.
Your Data may continue to be accessed by others until they refresh their cache.
Please note that AFEA will not delete or restrict access to Data about you where you have published in an AFEA journal or other AFEA publication including Division journals and/or newsletters. We will not delete historical Data that reference your service to AFEA or its Divisions in governance. We will not delete any comments or posts you have made on any of AFEA's social media accounts or on any other of AFEA's Digital Assets.
Your California privacy rights
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding the AFEA’s disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us at email@example.com.
How we respond to do not track signals
The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.
AFEA Digital Assets, and the services AFEA provides to its Users, are not directed to or intended for individuals under the age of 16. We do not knowingly collect Personal Data from children under 16. If we become aware that a child under the age of 16 has provided us with Personal Data, we will take steps to delete such information. If you become aware that a child under the age of 16 has provided us with Personal Data, please contact us at firstname.lastname@example.org.
Users may contact AFEA’s Data Protection Officer through email at email@example.com.
Consent to transfer
EU user consent
For Users of this website located in the European Union (“EU”), AFEA follows the Google EU User Consent Policy found at this link: http://www.google.com/about/company/user-consent-policy.html. By voluntarily using this website, EU Users consent to AFEA’s data collection, sharing, and usage as described above.
EU data subjects
This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein, Norway, the United Kingdom and, where applicable, Switzerland).
AFEA is the data controller for processing Personal Data provided to us through AFEA Digital Assets.
We collect and use Personal Data when we have a lawful basis to do so, as follows:
• At your direction and with your consent.
• To fulfill contracts we might have with you.
• For public interest.
• For vital interests.
• For other legitimate business purposes.
• To comply with a legal obligation.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Subject to applicable law, you have the following rights in relation to your Personal Data:
• Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
• If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
• If we are processing your Personal Data for direct marketing.
• Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless such profiling is necessary for entering into, or the performance of, a contract between you and us. AFEA does not make decisions based solely on automated processing.
• Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
• Right to anonymity: You have the right to request anonymity. This means that your Personal Data would not be collected or processed. If you choose to exercise this right, we may not be able to provide you with your requested goods or services.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
How we protect your personal data
We provide reasonable security controls to protect electronic Data that we receive from you against foreseeable hazards, but please note that no data transmission over the Internet can be guaranteed to be 100% secure. In addition, use of email to transmit Data is insecure and violates AFEA policy. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the AFEA Digital Assets or providing information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the AFEA Digital Assets. We may post a notice via our AFEA Digital Assets if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
Additionally, we will update the “last updated” date below.
LAST UPDATED: March 2022