TIA
Privacy Policy and Cookie Policy
May 25, 2018

Background:
TIA understands that your privacy is important to you and that you care about how your information
is used and shared online. We respect and value the privacy of everyone who visits Our Site and will
only collect and use information in ways that are useful to you and in a manner consistent with yourrights and Our obligations under the law.
This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our
Privacy Policy is deemed to occur upon your first use of Our Site AND You will be required to read andaccept this Privacy Policy when signing up for an Account. If you do not accept and agree with thisPrivacy Policy, you must stop using Our Site immediately.

1.

Definitions and Interpretation
In this Policy the following terms shall have the following meanings:

2.

“Account”

means an account required to access and/or use certain
areas and features of Our Site;“Cookie”

means a small text file placed on your computer or device
by Our Site when you visit certain parts of Our Site and/or
when you use certain features of Our Site. Details of the
Cookies used by Our Site are set out in section 12, below;“Our Site”

means this website;“US and EU Cookie Law”

means the relevant parts of the Privacy and Electronic
Communications (EC Directive) Regulations 2003 as
amended in 2004, 2011 and 2015; and“We/Us/Our”

means TIA (Telecommunications Industry Association), a
limited company registered in Virginia, whose registeredaddress is 1320 North Courthouse Road, Suite 200
Arlington, VA 22201.

Information About Us
2.1

Our Site is owned and operated by ourselves

2.2

Our data protection officer is Andy Kurtzman who can be contacted at AKurtzman (at)Page 1|8

tiaonline (dot) org

3.

Scope – What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. It does not extend to any websites thatare linked to from Our Site (whether We provide those links or whether they are shared byother users). We have no control over how your data is collected, stored or used by otherwebsites and We advise you to check the privacy policies of any such websites before providing
any data to them.

4.

What Data Do We Collect?
Some data will be collected automatically by Our Site (for further details, please see section 12
on Our use of Cookies) other data will only be collected if you voluntarily submit it and consent
to Us using it for the purposes set out in section 5, for example, when signing up for an Account.
Depending upon your use of Our Site, We may collect some or all of the following data:

5.

4.1

Name;

4.2

date of birth;

4.3

gender;4.4

business/company name;

4.5

job title;

4.6

profession;

4.7

contact information such as email addresses and telephone numbers;

4.8

demographic information such as post code, preferences and interests;

4.9

financial information such as billing information;

4.10

IP address (automatically collected);

4.11

web browser type and version (automatically collected);

4.12

operating system (automatically collected); and4.13

a list of URLs starting with a referring site, your activity on Our Site, and the site you
exit to (automatically collected).

How Do We Use Your Data?
5.1

All personal data is stored securely. For more details on security see section 6, below.

5.2

We use your data to provide the best possible products and services to you. This
includes:5.2.1

Providing and managing your Account;

5.2.2

Providing and managing your access to Our Site;

5.2.3

Personalising and tailoring your experience on Our Site;

5.2.4

Supplying Our products and services to you;

5.2.5

Personalising and tailoring Our products and services for you;

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5.2.6

Responding to communications from you;

5.2.7

Supplying you with email e.g. newsletters, alerts etc. that you have subscribedto (you may unsubscribe or opt‐out at any time using the unsubscribe link atthe bottom of such emails;

5.2.8

Market research;

5.2.9

Analysing your use of Our Site and gathering feedback to enable Us tocontinually improve Our Site and your user experience; and5.2.10 Fraud prevention.

6.

5.3

In some cases, the collection of data may be a statutory or contractual requirement,
and We will be limited in the products and services We can provide you without yourconsent for Us to be able to use such data.

5.4

With your permission and/or where permitted by law, We may also use your data formarketing purposes which may include contacting you by email AND/OR telephone
AND/OR text message AND/OR post with information, news and offers on Our
products AND services. We will not, however, send you any unsolicited marketing or
spam and will take all reasonable steps to ensure that We fully protect your rights andcomply with Our obligations under the GDPR and the Privacy and Electronic
Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.5

Under GDPR we will ensure that your personal data is processed lawfully, fairly, andtransparently, without adversely affecting your rights. We will only process yourpersonal data if at least one of the following basis applies:a)you have given consent to the processing of your personal data for one or more
specific purposes;b)processing is necessary for the performance of a contract to which you are aparty or in order to take steps at the request of you prior to entering into acontract;c)

processing is necessary for compliance with a legal obligation to which we aresubject;d)processing is necessary to protect the vital interests of you or of another natural
person;e)

processing is necessary for the performance of a task carried out in the public
interest or in the exercise of official authority vested in the controller; and/or

f)processing is necessary for the purposes of the legitimate interests pursued by
us or by a third party, except where such interests are overridden by thefundamental rights and freedoms of the data subject which require protectionof personal data, in particular where the data subject is a child.

How and Where Do We Store Your Data?
6.1

We only keep your data for as long as We need to in order to use it as described above
in section 5, and/or for as long as We have your permission to keep it. In any event,
We will conduct an annual review to ascertain whether we need to keep your data.
Your data will be deleted if we no longer need it in accordance with the terms of our
Data Retention Policy.

6.2

Your data may be stored or transferred in the USA. We will take all reasonable steps
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to ensure that your data is treated as safely and securely as it would be within the EEA
and under the GDPR.
6.3

Data security is of great importance to Us, and to protect your data We have put inplace suitable physical, electronic and managerial procedures to safeguard and securedata collected through Our Site.

6.4

Steps We take to secure and protect your data include:

6.5

6.4.1

https for website access

6.4.2

restricted use of FTP

6.4.3

security hardening of server software

6.4.4

regular patching of server software

6.4.5

security audits

Notwithstanding the security measures that We take, it is important to remember thatthe transmission of data via the internet may not be completely secure and that you
are advised to take suitable precautions when transmitting to Us data via the internet.
How long we keep information

How long we keep information we collect about you depends on the type of information, as describedin further detail below. After such time, we will either delete or anonymize your information or, if thisis 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.
Account information: We retain your account information until you delete your account. We
also retain some of your information as necessary to comply with our legal obligations, toresolve disputes, to enforce our agreements, to support business operations and to continue
to develop and improve our Services. Where we retain information for Service improvementand development, we take steps to eliminate information that directly identifies you, and weonly use the information to uncover collective insights about the use of our Services, not to
specifically analyze personal characteristics about you.
Managed accounts: If the Services are made available to you through an organization (e.g.,
your employer), we retain your information as long as required by the administrator of youraccount.
Marketing information: If you have opted to receive marketing emails from us, we retain
information about your marketing preferences unless you specifically ask us to delete suchinformation. We retain information derived from cookies and other tracking technologies fora reasonable period of time from the date such information was created.

7.

Do We Share Your Data?
7.1

We may share your data with other companies in Our group. This includes Our
subsidiaries AND/OR Our holding company and its subsidiaries.

7.2

We may contract with third parties to supply products and services to you on Our
behalf. These may include software development, payment processing, delivery ofPage 4|8

goods, search engine facilities, advertising and marketing. In some cases, the third
parties may require access to some or all of your data. Where any of your data isrequired for such a purpose, We will take all reasonable steps to ensure that your data
will be handled safely, securely, and in accordance with your rights, Our obligations,and the obligations of the third party under the law.

8.

9.

10.

7.3

We may compile statistics about the use of Our Site including data on traffic, usage
patterns, user numbers, sales and other information. All such data will be anonymised
and will not include any personally identifying information. We may from time to timeshare such data with third parties such as prospective investors, affiliates, partners andadvertisers. Data will only be shared and used within the bounds of the law.

7.4

In certain circumstances We may be legally required to share certain data held by Us,
which may include your personal information, for example, where We are involved inlegal proceedings, where We are complying with the requirements of legislation, a
court order, or a governmental authority. We do not require any further consent fromyou in order to share your data in such circumstances and will comply as required withany legally binding request that is made of Us.

What Happens If Our Business Changes Hands?
8.1

We may, from time to time, expand or reduce Our business and this may involve thesale and/or the transfer of control of all or part of Our business. Data provided by users
will, where it is relevant to any part of Our business so transferred, be transferredalong with that part and the new owner or newly controlling party will, under theterms of this Privacy Policy, be permitted to use the data for the purposes for which it
was originally collected by Us.

8.2

In the event that any of your data is to be transferred in such a manner, you will not
be contacted in advance and informed of the changes.

How Can You Control Your Data?
9.1

When you submit information via Our Site, you may be given options to restrict Our
use of your data. We aim to give you strong controls on Our use of your data (including
the ability to opt‐out of receiving emails from Us which you may do by unsubscribing
using the links provided in Our emails and by managing your Account).

9.2

You may also wish to sign up to one or more of the preference services operating in
the USA: The Telephone Preference Service (“the TPS”), the Corporate Telephone
Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”).
These may help to prevent you receiving unsolicited marketing. Please note, however,that these services will not prevent you from receiving marketing communications thatyou have consented to receiving.

Your Right to Withhold Information and Your Right to Withdraw Information After
You Have Given it
10.1

You may access the login page Our Site without providing any data at all. However, touse all features and functions available on Our Site you may be required to submit orallow for the collection of certain data.

10.2

You may restrict your internet browser’s use of Cookies. For more information, see
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section 12.
10.3

11.

You may withdraw your consent for Us to use your personal data as set out in sectionin 5 at any time by contacting Us using the details set out in section 15, and We will
delete Your data from Our systems. However, you acknowledge this may limit Our
ability to provide the best possible products and services to you.

How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where suchdata is held). Please have your organization administrator contact Us for more details by using
the contact details below in section 15.

Children
The Services are not directed to children (individuals under the age of 16). We do notknowingly collect personal information from children. If we become aware that a child has
provided us with personal information, we will take steps to delete such information.

12.

CookiesOur Site may place and access certain first party Cookies on your computer or device. First
party Cookies are those placed directly by Us and are used only by Us. We use Cookies tofacilitate and improve your experience of Our Site and to provide and improve Our products
and services. By using Our Site you may also receive certain third party Cookies on yourcomputer or device. Third party Cookies are those placed by websites, services, and/or parties
other than Us. We use third party Cookies on Our Site for marketing and advertising. In
addition, Our Site uses analytics services provided by Google, which also use Cookies. Website
analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us tobetter understand how people use Our Site.

13.

How to access and control your information

Below is a summary of your choices about your data, how to exercise them and any limitations. We
will respond to requests about this within a reasonable timeframe. Where the Services areadministered for you by an administrator you may need to contact your administrator to assist withyour requests first.
Your Choices:
You have the right to request a copy of your information, to object to our use of your information(including for marketing purposes), to request the deletion or restriction of your information, or torequest 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 the Services and using settings available within the Services or your account.
Where the Services are administered for you by an administrator you may need to contact youradministrator to assist with your requests first. For all other requests, you may contact us 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
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reveal information about another person, or if you ask to delete information which we or youradministrator are permitted by law or have compelling legitimate interests to keep. If you haveunresolved 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 Services give you the ability to access and update
certain information about you from within the Service.
Delete your information: Our Services gives you the ability to delete certain information about
you from within it. However, 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 us to stop accessing,storing, using and otherwise processing your information where you believe we don't have theappropriate rights to do so. For example, if you believe a Services account was created for you
without your permission or you are no longer an active user, you can request that we delete
your account as provided in this policy. Where you gave us consent to use your information
for a limited purpose, you can contact us 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 yourinformation for marketing 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 a 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 honored or the dispute is resolved,
provided your administrator does not object (where applicable).
Opt out of communications: You may opt out of receiving marketing communications from us
by using the unsubscribe link within each email. Even after you opt out from receiving
promotional messages from us, you will continue to receive transactional messages from us
regarding our site. You can opt out of some notification messages in your account settings.
Please note, you will continue to receive generic ads.
You may be able to opt out of receiving personalized advertisements from other companies who aremembers of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance's
Self‐Regulatory Principles for Online Behavioral Advertising. To enforce any of the foregoing rights or
if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details
set out in section 15 below.

14.

Automated Decision‐Making and Profiling
14.1

In the event that We use personal data for the purposes of automated decision‐making
and those decisions have a legal (or similarly significant effect) on You, You have theright to challenge to such decisions under GDPR, requesting human intervention,
expressing their own point of view, and obtaining an explanation of the decision from
Us.

14.2

The right described in section 14.1 does not apply in the following circumstances:a)

The decision is necessary for the entry into, or performance of, a contract
between the You and Us;
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14.3

15.

b)

The decision is authorised by law; orc)

You have given you explicit consent.

Where We use your personal data for profiling purposes, the following shall apply:a)

Clear information explaining the profiling will be provided, including its
significance and the likely consequences;b)

Appropriate mathematical or statistical procedures will be used;c)Technical and organisational measures necessary to minimise the risk of errors
and to enable such errors to be easily corrected shall be implemented; andd)All personal data processed for profiling purposes shall be secured in order toprevent discriminatory effects arising out of profiling.

Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at AKurtzman(at) tiaonline (dot) org, or by post at 1320 North Courthouse Road, Suite 200, Arlington, VA 22201,
USA. Please ensure that your query is clear, particularly if it is a request for information about the data
We hold about you (as under section 11, above).

16.

Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be requiredby law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted
the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommendthat you check this page regularly to keep up‐to‐date.

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