Effective September 12, 2018
Applicability & Eligibility
Eligibility To Use The Services
The Services are not directed to children under the age of 16. You may not use the Services if you are under the age of 16.
Information Collection & Use
OTA collects data about you and your use of the Services Personal Data as defined below, through various means, including when you provide information to us such as when you join, sign up for a membership, donate, register for events and webinars, participate in OTA surveys and when we automatically collect information about you when you access, use, or interact with the Services. We use this information for a variety of different reasons, including to improve the Services and to tailor the Services to you.
OTA processes Personal Data collected through the Services on the lawful basis of legitimate interests to provide the Services to you. Such processing is necessary for the purposes of the legitimate interests pursued by OTA or by our Service Providers related to the Services.
The types of information OTA may collect about you include:
Information You Provide To Us:
OTA Membership & Event Information: OTA collects certain Personal Data from you when you join the OTA or register for OTA events. “Personal Data” refers to information about you that may be used to identify you, such as your first name, last name, title, gender, date of birth, email address, phone number, mailing address and professional information. OTA uses this information to provide your membership, include your information in the OTA member directory, the Find a Surgeon Directory, register you for events, process your purchases, provide information about memberships and events, and administer your registrations with OTA.
OTA Account Information: OTA may require you to register for an account (a “OTA Account”) in order to use certain Services. We do not require you to register to use all of our Services. However if you do register for Services offering an OTA Account, you will gain access to those areas and features of the Services that require registration. OTA will collect certain information about you in connection with your registration for your OTA Account, which may include Personal Data and other information such as a username, password, personal profile, pictures, your location, and information about your contacts and social media usage. Some of your OTA Account information may be displayed publicly. You are not required to provide your Personal Data; however, if you choose to withhold certain Personal Data, we may not be able to provide you with certain Services.
Payment Transaction Information: We may collect and store information related to purchases and donations made through the Services. You may provide certain information to complete payments via the Services, including your credit or debit card number, card expiration date, CVV code, and billing address (collectively, “Payment Information”), along with your name and billing, delivery and shipping address, to complete payment transactions through certain Services.
Please note OTA works with Service Providers (as defined below) to handle payment transactions. OTA does not itself collect or maintain your credit card or other financial account information; this information is handled for OTA by our Service Providers. You are subject to the Privacy Policies and Terms and Conditions of our Service Providers when purchasing an OTA membership, shopping for OTA products, registering for OTA events, or making donations, the terms of which may differ from those of OTA for the OTA Services. Please review the Service Providers’ Privacy Policies and Terms and Conditions before using their services.
Form Information: We may use online forms to request certain information from you in order to perform certain Services, such as your location to assist you in locating our products, or your contact information to assist with contacts or service requests. This information may include Personal Data.
Correspondence Information: If you sign up for a membership, attend a conference or event, email us, subscribe to our newsletters mailing lists, publications, or blogs, we may keep your message, email address, and contact information to respond to your requests, provide the requested products or Services, and to provide notifications or other correspondences to you. If you do not want to receive email from us in the future, you may let us know by sending us an email or by writing to us at the address below. Please note requests to remove your email address from our lists may take some time to fulfill. We may also still contact you as needed to provide important announcements or notifications regarding the Services and information related to membership or products and services ordered by you.
Support Information: You may provide information to us via a support request submitted through the Services. We will use this information to assist you with your support request and may maintain this information to assist you or other Users with support requests. Please do not submit any information to us via a support submission, including confidential or sensitive information that you do not wish for OTA or our Service Providers to have access to or use in the future.
Information We Collect Automatically:
Trackers on the OTA site are:
Google Analytics, Google Tag Manager, and GA Audiences - see https://privacy.google.com/take-control.html
Unique Identifiers: When you use or access the Services, we may access, collect, monitor, store on your device, and/or remotely store one or more "Unique Identifiers," such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Services. Some features of the Services may not function properly if use or availability of Unique Identifiers is impaired or disabled.
Log File Information: When you use our Services, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Services, for example, when you visit our websites, sign into our Services, or interact with our email notifications. OTA uses log file data to provide, understand, and improve our Services, and to customize the content we show you. OTA may link this log file to other information OTA collects about you via the Services.
OTA Personnel: OTA’s personnel may have access to your information as needed to provide and operate the Services in the normal course of business. This includes information regarding your use and interaction with the Services.
Service Providers: OTA works with various organizations and individuals to help provide the Services to you ("Service Providers"), such as OTA’s journal publication, meeting vendors, website and data hosting companies and companies providing analytics information, like Google Analytics. We may share your personal information with our Service Providers for the purpose of providing the Services. The information we share to our Service Providers may include both information you provide to us and information we collect about you, including Personal Data and information from data collection tools like cookies, web beacons, log files, Unique Identifiers, and location data. OTA takes reasonable steps to ensure that our Service Providers are obligated to reasonably protect your information on OTA’s behalf. If OTA becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.
Business Transactions: OTA may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including Personal Data, may be among assets sold or transferred as part of a Business Transaction.
OTA Annual Meeting: OTA annual meeting exhibitors may purchase the mailing list (consisting of name and mailing address) of annual meeting attendees to provide information related to the exhibitor and its annual meeting booth.
Your Rights and Choices Regarding Your Information
Relevant data protection laws provide you certain rights regarding the protection of your data, including:
- the right to access - Upon request, OTA will confirm any processing of your Personal Data and, and provide you with a copy of that Personal Data in an acceptable machine-readable format;
- the right to rectification - You have the right to have OTA correct any inaccurate Personal Data or to have OTA complete any incomplete Personal Data;
- the right to erasure - You may ask the OTA 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);
- the right to restrict processing - You have the right to ask OTA to suppress the processing of your Personal Data but OTA may still store your Personal Data;
- the right to object to processing - You have the right to object to your Personal Data used in the following manners: (a) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (b) direct marketing (including profiling); and (c) processing for purposes of scientific/historical research and statistics;
- the 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 fulfillment of member benefits with you. We will give you your Personal Data in a structured, commonly used and machine-readable format;
- the right to complaint to a supervisory authority - You have the right to file a complaint with a supervisory authority, in particular in the European Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of Personal Data relating to you infringes upon your rights; and
- the right to withdraw consent - 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.
Access To The Information OTA Has Collected About You
OTA provides certain tools and settings within the Services to help you access, correct, delete, or modify your personal information associated with the Services. OTA welcomes you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Services uses of your information, or to withdraw any consent you may have granted to OTA.
Please note requests to delete or remove your information do not necessarily ensure complete or comprehensive removal of the content or information posted, and removed information may persist in backup copies indefinitely. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Services, may no longer be available to you.
We may store the information we collect about you indefinitely, but information generally will be retained only for as long as necessary to fulfill the purposes for which the information was collected, or as otherwise required by law. Following termination or deactivation of an OTA Account, OTA may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.
Opting-Out Of Communications From OTA
Users may opt-out of receiving certain communications from OTA by following the unsubscribe process described in an email communication, or by contacting us using the contact information provided below. However, please note you may not opt-out of Services-related communications, such as purchase transaction details, account verification, changes or updates to features of the Services, or technical and security notices.
Do Not Track
OTA does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including Personal Data, about your online activities over time and across different websites or online services when you use Services. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
Security Of Your Information
OTA takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration and destruction. OTA implements security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, OTA cannot guarantee the security of our systems or databases, nor can we guarantee that personal information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Services is provided at your own risk.
Please do your part to help us keep your information secure. You are responsible for maintaining the confidentiality of your password and OTA Account, and are fully responsible for all activities that occur under your password or OTA Account. OTA specifically reserves the right to terminate your access to the Services and any contract you have with OTA related to the Services in the event it learns or suspects you have disclosed your OTA Account or password information to an unauthorized third party.
Additional Provisions Regarding The Services & Your Information
Transfer And Storage Of Your Information
Please note information OTA collects about you may be transferred, processed and/or accessed by us in the United States, or another country where we, or our Service Providers operate. Please be aware Personal Data may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that OTA may transfer your Personal Data to the United States and process and store it there.
Website Hosting: OTA works with Rackspace as its web hosting services provider. Rackspace is located in San Antonio, Texas and the Website are stored by Rackspace in San Antonio,Texas. OTA shares your data, including Personal Data for the purposes of processing your data pursuant to your use of the Services.
Data Hosting: OTA works with ACGI as its data hosting services provider. ACGI is located in Columbia, Maryland and OTA’s data are stored by ACGI in Columbia, Maryland. OTA shares your data, including Personal Data for the purposes of processing your data pursuant to your use of the Services.
Safely Using OTA’s Services
Despite OTA’s safety and privacy controls, we cannot guarantee the Services are entirely free of illegal, offensive, pornographic, or otherwise inappropriate material, or that you will not encounter inappropriate or illegal conduct from other Users when using the Services. You can help OTA by notifying us of any unwelcome contact by contacting us using the information below.
Your California Privacy Rights
Under California Civil Code Section 1798.83 (known as the "Shine the Light" law), OTA members and customers who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at Caswell@ota.org with "Request for California Privacy Information" on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
Data Protection Officer
Orthopaedic Trauma Association
9400 W. Higgins Road, Suite 305
Rosemont, IL 60018-4975