Last Updated: January 16, 2019
What this policy covers
The privacy of all individuals that interact with the Cold Pressure Council (CPC) is extremely important to us, as is CPC’s ability to be transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
- What information we collect about you
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- How to access and control your information
- Other important privacy information
This policy applies to (hereafter collectively referred to as CPC):
- The Cold Pressure Council (CPC) with offices located in Reston, VA
- All staff and contractors of CPC
- All suppliers and vendors, and any individual or company working on behalf of CPC
What information we collect about you
CPC collects information about you when you provide it to us or when you use CPC’s Offerings, or when it is provided by one of CPC’s vendors or suppliers working in support of our Offerings by interacting with you.
Information you provide to CPC
We collect information about you when you input it into CPC’s Offerings or otherwise provide it directly to CPC. That information typically includes the following:
- Employer and Title
- Contact information (Address, Phone number(s), E-mail address)
- Payment information (typically in the form of credit card or check information)
CPC does not collect sensitive Personally Identifiable Information (PII) such as social security numbers, or Protected Health Information (PHI).
Account and Profile Information: We collect information about you when you register for an account on our website or a vendor’s/supplier’s website, create or modify your profile, set preferences, sign-up for e-mails or newsletters, or make purchases through CPC’s Offerings or Websites. For example, you provide your contact information and, in some cases, billing information when you register for different CPC Offerings. In cases where you provide payment information to CPC, such as a credit card or bank account number, these are processed by our vendor’s or supplier’s systems and not stored in CPC systems. We also keep track of your e-mail preferences when you select settings within our Offerings.
Content you provide through our websites or social media: CPC’s Offerings also include our websites and mobile applications owned or operated by CPC. We collect other content that you submit to these websites, which include social media handles operated by CPC. For example, you provide content when you send feedback or when you participate in any interactive features, surveys, contests, promotions, activities or events.
Information you provide through our Digital channels: Our Offerings also include our Membership and Digital Support teams, where you may choose to submit information regarding an order you would like to place or a problem you are experiencing. Whether you designate yourself as a contact, submit a support request, speak to one of our staff members directly or otherwise engage with our Membership or Digital support teams, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment Information: We collect certain payment and billing information when you register for certain paid Offerings. For example, we ask you to designate a billing representative, including name and contact information, upon membership or meeting registration. You might also provide payment information, such as payment card details, which we collect via our vendor’s secure payment processing Offerings, such as meetings registrations or report downloads.
Information we collect automatically when you use our Offerings
We collect information about you when you use our Offerings, including browsing our websites and taking certain actions within those websites.
Your use of our Offerings: We may track certain information about you when you visit and interact with any of our Offerings. This information includes your engagements with CPC; the features you use; newsletters and e-mails you receive; events, or webinars you attend; the links you click on; the downloads or uploads you complete; and how you interact with CPC using our Offerings. We also capture information about any on-site visits that CPC staff may make to your facilities.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access CPC’s websites and Offerings. This device information includes your connection type and settings when you install, access, update, or use our Offerings. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. How much of this information we collect depends on the type and settings of the device you use to access our Offerings and Websites.
Information we receive from other sources
We receive information about you from other users within CPC’s Offerings, from third-party services, from our related companies, and from our business and channel partners.
Other users of CPC’s Offerings: Other users of CPC’s Offerings may provide information about you when they submit requests through our Offerings. For example, you may be mentioned by a membership or billing contact. We also receive your email address from other users when they provide it to invite you to CPC’s Offerings or Events. Similarly, another user may provide your contact information when they designate you as the billing or other type of contact on your company’s record.
Other Partners: We receive information about you and your activities on and off of CPC’s Digital Offerings from third-party partners, such as advertising, media and publishing, and research partners who provide CPC with information about your interest in and engagement with our Offerings and online advertisements.
How we use information we collect
How we use the information we collect depends in part on which of CPC’s Offerings you use, how you use them, and any preferences you have communicated to CPC. Below are the specific purposes for which we use the information we collect about you.
To deliver CPC’s Offerings and personalize your experience: CPC uses information about you to provide our Offerings to you, including to process transactions with you, authenticate you when you log in, provide support, and operate and maintain our Offerings and Websites. Our Offerings also include tailored features that personalize your experience, enhance your productivity, and enable you to find content that is most relevant for you. We use your email domain to infer your affiliation with a particular organization or member company to personalize the content and experience you receive on our websites. Where you may engage with multiple CPC Offerings, we combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one Website while searching from another or to present relevant product information as you travel across our websites.
For research and development: We are always looking for ways to make our Offerings smarter, faster, integrated, more secure, and useful to you. We use collective learnings about how people use our Offerings and feedback provided directly to CPC to troubleshoot and to identify trends, usage, activity patterns and areas for integration and enhancement of our Offerings. In some cases, we apply these learnings across our Offerings to improve and develop similar features or to better integrate our Offerings you use. We also test and analyze certain new features with small groups of users before rolling the feature out.
To communicate with you about our Offerings: We use your contact information to send communications via e-mail and through other mediums such as social media. We may send you e-mail blasts, newsletters, industry updates, marketing for events and trade shows, and may also send you targeted advertisements. We also provide tailored communications based on your activity and interactions with CPC. Opt-out mechanisms are made available to you in the footer of our e-mail communications and through our privacy policies, you will find those mechanisms within the communication itself or in the communication preferences center.
To market, promote and drive engagement with our Offerings: We use your contact information and information about how you use our Offerings to send promotional communications that may be of specific interest to you, including by e-mail and by displaying advertisements of CPC’s services and events, as well as on social media platforms like Facebook, LinkedIn, and Adaptive. These communications are aimed at driving industry engagement and maximizing the value that you receive from CPC’s Offerings, including information about industry developments, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offerings, promotions and contests. You can control whether you receive these communications as described below under “Opt-out of communications.”
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger, sale, or management of a business.
With your consent: We use information about you where you have given CPC consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured stories to promote our Offerings, with your express permission.
Legal basis for processing (for EU citizens):
If you are a citizen of the European Union (EU), we collect and process information about you only where we have legal basis for doing so under applicable EU laws. The legal basis depends on our Offerings you use and how you use them. This means we collect and use your information only where:
- We need it to provide you our Offerings, including to operate our Offerings, provide support and personalized features and to protect the integrity and security of our Offerings;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for industry information and engagement, to market and promote our Offerings and to protect our legal rights and interests;
- You provide CPC unambiguous, explicit consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. a vendor or industry partner) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may result in you no longer using CPC’s Offerings.
How we share information we collect
CPC’s purpose is to lead, facilitate, and promote industry standardization, user education, and consumer awareness of High Pressure Processing (HPP) and to address questions about HPP while developing and formalizing industry best practices. This sometimes means sharing information through our Offerings and with certain third-parties for purposes of industry engagement. We share information we collect about you in the ways discussed below, including in connection with possible business opportunities.
Sharing with third parties
We share information with third-parties that help CPC operate, provide, improve, integrate, customize, support and market our Offerings, including PMMI, the Association for Packaging and Processing Technologies.
Service Providers: We work with third-party service providers to provide application and database services (including mobile applications), website development and hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for CPC, which may require them to access or use information about you. We also share information about you for purposes of delivering a particular service to you, such as a meeting, event, or webinar. If a service provider needs to utilize information about you to perform services on our behalf, they do so under close instruction from CPC, including policies and procedures designed to protect your information.
Links to Third-Party Sites: CPC’s Offerings may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies and not this policy. We encourage you to carefully read the privacy policies and cookie tracking policies of any website you visit or services you utilize.
Social Media Widgets: Our Offerings may include links that direct you to other social media websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this policy.
CPC utilizes Facebook and Google Adwords for purposes of advertising CPC events and meetings. These advertisements are targeted in nature to specific audiences and utilize both distribution lists from CPC systems and databases as well as targeting data made available through Facebook to determine the targeted audience. Information used for targeting includes:
- Individuals who like CPC’s Facebook page
CPC also uses Facebook’s “look-alike” feature to identify individuals with similar attributes and profiles to other individuals within the target audience. Google Adwords is also used to advertise as well, however, no targeting based on individually identifiable social media attributes is done using Google, only targeting for specific search terms.
With your consent: We share information about you with third-parties when you provide your consent to do so. For example, we may display personal testimonials or user stories on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third-party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect CPC, our members, or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires CPC to disclose information to assist in preventing the death or serious bodily injury of any person.
How we store and secure information we collect
Information storage and security
We use server, data, application, and website hosting service providers based in the United States to store the information we collect, and we use technical measures to secure your data.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is 100% safe from intrusion by others. CPC will make its best efforts in good faith to ensure that systems and databases under its control are appropriately secured, and that service providers and vendors utilized conform with leading cybersecurity practices.
How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Member information: We retain your member information for as long as your membership is active with CPC and a period of five years thereafter for council membership records. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Offerings. Where we retain information for business operations, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Offerings, not to specifically analyze personal characteristics about you.
Marketing information: If you have elected to receive communications from CPC, we retain information about your communication preferences in perpetuity in order to properly honor all unsubscribe requests we receive. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
You have the right to request a copy of your information, to object to our use of your information (including for marketing/communication purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into our web-based Offerings and using settings available within your account. For all other requests, you may contact CPC as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which CPC is permitted by law or have compelling legitimate interests to keep. Where you have consented to share data with third parties, for example, by attending a CPC Meeting, CPC will take responsibility for contacting those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
Access and update your information: Our Offerings provide you the ability to access and update certain information about you, such as within the member portal of the CPC website or through a vendor website. For example, you can access your profile information from your account and update your information.
Deactivate your account: If you no longer wish to use our Offerings, please contact CPC as provided in the Contact Us section below to request assistance. Please be aware that deactivating your account does not delete your information; your information remains visible to CPC staff based on your past participation within our Offerings.
Delete your information: Our Offerings provide you the ability to delete certain information about yourself from within our Offerings. For example, you can remove certain personal information from the member portal of the CPC website. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
Request that we stop using your information: In some cases, you may ask CPC to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe you were opted into marketing/communications without your permission or you are no longer an active user of CPC’s Offerings, you can request that we delete your account as provided in this policy. Where you gave CPC consent to use your information for a limited purpose, you can contact CPC to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for communications purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is resolved. If you object to information about you being shared with a third-party, please contact CPC as provided in the Contact Us section below to request assistance.
Opt out of communications: You may opt out of receiving communications from CPC by using the unsubscribe link within each email, updating your email preferences within your communication preferences center, or by contacting CPC as provided below to have your contact information removed from our email list or membership/CRM database.
You may be able to opt out of receiving targeted advertisements from other companies who are suppliers or services providers of the packaging and processing industries. If you have any difficulty adjusting your preferences or opting out of communications, you may always send an inquiry to our central Data Privacy mailbox, dataprivacy@Pmmi.org.
Cookie and Web Beacon Policy:
CPC and our third-party partners, such as our advertising and analytics partners, use various technologies to collect information, such as cookies and web beacons.
What types of technologies do we use?
How do we use them?
- Where strictly necessary. These cookies and other technologies are essential to enable our Offerings to provide value to you.
- For performance and analytics. These cookies and similar technologies collect information on how users interact with our Offerings and enable CPC to improve how our Offerings operate. For example, we use Google Analytics cookies to help CPC understand how visitors arrive at and browse our websites to identify areas for improvement such as navigation, user experience, and marketing campaigns.
- Targeting Cookies or Advertising Cookies. These cookies collect information about your actions when visiting CPC websites or opening communications from CPC, to make advertising relevant to you and your interests. They remember the CPC websites you have visited and that information may be shared with other parties such as advertisers and advertising technology service providers.
- Social media cookies. Similar to targeting or advertising cookies, these cookies are used to identify you when you browse or engage with our content on or through a social media site for purposes of advertisement targeting.
How can you opt-out?
Many browsers include their own management tools for removing HTML5 local storage objects. You may be able to opt out of receiving personalized advertisements as described under “Contact Us”.
Send “Do Not Track” Signals: Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Offerings do not currently respond to browser DNT signals.
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic personally identifiable information that we have stored in our systems, such as name, contact information, and employment relationships.
How we transfer information we collect internationally
International transfers of information we collect
We collect information globally and primarily store that information in the United States. If we do transfer, process and store your information outside of your country of residence, we do so to wherever CPC or our third-party service providers operate for the purpose of providing you CPC’s Offerings. Whenever we transfer your information, we take steps to protect it.
Privacy Shield Notice
Under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, we are responsible for the processing of information about you we receive from the EU and Switzerland and onward transfers to a third-party acting as an agent on our behalf. We comply with the Privacy Shield Principles for such onward transfers and remain liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such information about you on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
To learn more about the Privacy Shield Program, and to view CPC’s certification, please see here https://www.privacyshield.gov.
We encourage you to contact us as provided below should you have a Privacy Shield-related (or general privacy-related) complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the EU Data Protection Authorities or Swiss FDPIC. Through the dispute resolution process, we have also committed to cooperating and complying with the information and advice provided by an informal panel of data protection authorities in the European Economic Area and/or the Swiss Federal Data Protection and Information Commissioner (as applicable) in relation to unresolved complaints (as further described in the Privacy Shield Principles). You may also contact your local data protection authority within the European Economic Area or Switzerland (as applicable) for unresolved complaints.
Under certain conditions, more fully described on the Privacy Shield website, including when other dispute resolution procedures have been exhausted, you may invoke binding arbitration.
We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Other important privacy information
Our policy towards minors
Our Offerings are not directed to individuals under the age of 14. We do not knowingly collect personal information from minors under age 14. If we become aware that a minor under the age of 14 has provided CPC with personal information, we will take steps to delete such information. If you become aware that a minor has provided CPC with personal information, please contact dataprivacy@Pmmi.org.
Your information is controlled by CPC. If you have questions or concerns about how your information is handled, please direct your inquiry to CPC at:
The Cold Pressure Council
12930 Worldgate Drive, Suite 200
Herndon, VA 20170
Phone: (571) 612-3200