By visiting the Site, or using any of our Services, you acknowledge that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Naylor Terms of Service are incorporated by reference into this Policy.
The Information We Collect About You
We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.
Information We Collect Directly From You
The type of information we collect depends on how you use our Site and Services. When you use the Site or Services to manage your publication’s advertisements, we will collect your project code, advertiser code, your name, username and password, order number, your company name, your email address, and your phone number. If you order article reprints, we will collect your email address, shipping address, phone number, your company name, and information about the publication you are requesting reprints from. If you make a renewal payment through the Site, we will collect your username, password, your order number and publication code, and your payment information. If you contact us with an inquiry or request, we will collect your name, email address, business information, and the contents and purpose of your communication.
Information We Collect Automatically
We may automatically collect the following information about your use of our Site or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the web page that led you to our Site. We may combine this information with other information that we have collected about you, including, where applicable, your personal information Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
To tailor the content and information that we may send or display to you, to personalize help and instructions, and to otherwise personalize your experiences while using the Site or our Services.
For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Services on third party websites.
To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.
To administer surveys and questionnaires.
To protect our own rights and interests, such as to resolve any disputes, enforce our Terms of Service, and to respond to legal process.
How We Share Your Information
We may share your information, including personal information, as follows:
We may share information we collect from you with our customers (e.g., your association or company), about our services for them, such as to confirm orders or for billing purposes.
We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
If we are acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
In Response to Legal Process
We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
To Protect Us and Others
Aggregate and De-Identified Information
We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags and other technologies
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Third Party Analytics
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
Third-Party Ad Networks
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Online Behavioral Advertising and How You Can Opt-Out
We may work with third-party advertising companies who may utilize cookies and web beacons, and data collected on our services, to customize advertisements to you on our services, as well as on other websites or mobile applications in their networks beyond our services. Among other things, these customized advertisements may advertise our products and services and third party products and services on websites or mobile applications not affiliated with us. Some of these ads are online behavioral advertising – which serve advertisements that are more likely to be of interest to you using non-personal behavioral information. Such ads may contain cookies that allow monitoring of websites and mobile applications (including our own services) and your response to such advertisements. Cookies or web beacons placed by these companies do not collect personal information, and the third-party advertising companies do not have access to or use your name, address, e-mail address, telephone number or other personal information; they may however, anonymously track your usage across our services and other websites or mobile applications in their networks. We limit companies that place our ads from using information for any purpose other than to assist us in our advertising efforts.
For more information about these third-party advertising companies’ privacy policies, visit the Network Advertising Initiative’s website at http://www.networkadvertising.org. If you prefer to not receive targeted advertising, you can opt-out of network advertising programs that use your information. To do so, please visit: the Network Advertising Initiative’s opt-out page.
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of My Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access to My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
If you are a resident of the European Union or California, please see the Information for EU and California Individuals section below for additional information on accessing your information and other legal rights available to you under European Union law or the California Consumer Privacy Act.
What Choices Do I Have Regarding Promotional Communications?
We may send periodic promotional or informational emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Information We Collect as a Service Provider
At our customers’ request, we may also place advertisements on these customers’ websites. The advertisements we place are commonly known as contextual ads, which are ads based on the website you are currently visiting and are not based on what third-party websites you may have previously visited (otherwise known as targeted or behavioral ads). On behalf of our customers, we may track how visitors to the customers’ websites interact with or click on these advertisements so we can better manage the customers’ websites and place advertisements on those sites, but we do not use this information for our own purposes.
We also assist our customers by managing our customers electronic member newsletters.
Information for EU and California Individuals
The legal bases for using your personal information. We collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- Our use of your personal information is in accordance with your consent (for example, when you consent to sharing your personal information with an advertising sponsor in order to receive a complimentary session on the Services).
- Our use of your personal information is in our legitimate interest as a commercial organization (for example in order to make improvements to our products and services and to provide you with information you request); you have a right to object to processing as explained in the section below titled Your Legal Rights;
- Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example where we use your payment information when you purchase our Services); and/or
- Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).
If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.
Your Legal Rights
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, European Union individuals and California residents have certain rights in relation to your personal information:
Right to access, correct, and delete your personal information
You have the right to request access to the personal information that we hold about you and:(a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred. EU residents have access to data we have collected about you at any time; California residents have access to data we have collected within the past 12 months.
You also have the right to request that we delete your information.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or deference of legal claims.
Right to restrict the processing of your personal information
You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to data portability
To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
Right to object to the processing of your personal information
You can object to any processing (EU) or selling (California) of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA or California.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
How to Exercise Your Rights
If you would like to exercise any of the rights described above, please send us a request to GDPRrequest@naylor.com. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete. If you are a client of an association to which Naylor provides services, please include the name of the association and the product(s) you are using to help us direct your request.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Cross-border Transfer of Information
Naylor generally maintains servers and systems in the United States hosted by third party service providers. We also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States or countries other than your country of residence. As a result, where the personal information that we collect through or in connection with the Services is transferred to and processed in the United States or anywhere else outside the European Economic Area (EEA) for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the EEA.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us by calling 800-369-6220.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.
How to Contact Us
We welcome your questions and comments surrounding privacy. Please contact us at:
Naylor Association Solutions
1430 Spring Hill Road, 6th Floor
McLean, VA 22102
GDPRRequest@naylor.com (This email address is also appropriate for individuals wanting more information about their rights under the CCPA.)