Please note: The American Association of Private Lenders name, the acronym AAPL, as well as the AAPL logo, are exclusive service marks of The American Association of Private Lenders.
(Updated May 29, 2018)
It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
AAPL collects, uses, and discloses your Personal Information in its normal course of business. The information may be used to plan new products or services, gauge customer satisfaction, measure awareness of products or services, or to test reaction to products, services or communications. The American Association of Private Lenders is committed to respecting and protecting your privacy as a research respondent who is participating in a study. This policy explains how AAPL collects and uses data that AAPL obtains via surveys and other primary research methods that AAPL uses. If you are participating in one of AAPL’s research studies from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. Below are the primary uses of this information supplied to us:
- Establishing and maintaining communications with you;
- Providing requested content or services from AAPL;
- Responding to your inquiries about content and other services;
- Making proposals for future service needs;
- Allowing a partner to notify you of certain products, services or events offered by them;
- Processing transactions through vendors and/or service providers;
- Registration for conferences, training and other events;
- Meeting legal, security, processing and regulatory requirements;
- Protecting against fraudulent, suspicious or other illegal activities; and
- Compiling statistics for analysis of our sites and our business.
WHAT INFORMATION WE COLLECT
The information gathered by AAPL from its Sites falls into two categories: (1) information voluntarily supplied by visitors to our Site and other Products, and (2) tracking information gathered as visitors navigate through our Site.
Information Voluntarily Provided by You
When using AAPL’s Sites, you may choose to provide us with information to help us serve your needs. Personal Information is information recorded in any form that identifies an individual or can be used to identify an individual. It is not limited to include an individual’s name, identification numbers, date of birth, gender, mailing address, phone numbers, email address and other similar information. It may include information about an individual’s personal information and preferences.
You provide Personal Information to AAPL while participating in research directly to AAPL and utilizing AAPL products and services. In such cases, AAPL will comply with the contact limitations and data protections to which you agreed when you provided that permission. The AAPL may collect and use PERSONAL INFORMATION obtained from publicly available sources, where this is permitted by law. Most research surveys include demographic questions such as racial or ethnic origin, age, gender or income. AAPL uses these questions to help confirm that the research reflects a representative sample of the population AAPL is studying. AAPL also automatically collects information that is made available by the device you use to access AAPL’s websites for system administration, surveys, service improvements, data analysis, and data integrity purposes to ensure that survey respondents do not impermissibly duplicate participation in the same survey. The information automatically collected for this purpose, as well as other Personal Information may be shared with third parties for the purposes of detecting and preventing impermissible duplicate participation in the same survey.
Your participation is voluntary. You are entitled at any stage of the interview or survey, research or afterward, to ask that part or all your personal data be destroyed. Wherever reasonable and practical, we will carry out such a request.
Below are some additional ways we collect data:
- When you request content
- If you request content (e.g., Private Lender magazine, best practices, research) or further information from us, we require you to submit your name, email address, the name of your organization, and the country in which you are based so we may send you the material you have requested and to enable us to identify if you are an existing client of AAPL.
- Following an inquiry into receiving content or services from us, if you decide to proceed, we will collect Personal Information necessary to proceed with the transaction, such as your name, address, ZIP code, contact telephone number, email address, billing address or payment details, as relevant to the product. We will use your Personal Information to administer your account, fulfill registrations, and generally manage your relationship with us.
- When you register with us and/or join AAPL as a member
- If you register with the Site(s), request a service available on the Site(s) (such as registration for a conference), or become a member of the AAPL, we will ask you for your name, email address, country, telephone number, and may verify reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the service or identify what would be of most interest to you. On the data submission form, we shall indicate by way of an asterisk which information is optional and which information is mandatory.
- When you submit content
- If you submit content through our Sites, we will ask for your name and email address, so that, if you choose, we can update you by email when others also comment on the content and so that we can manage the content in line with our Code of Ethics. You should be aware that the information you provide there will be made publicly available to AAPL employees, AAPL members, and other users of the Sites.
Website Navigational Information
As you navigate AAPL’s Sites, we may also collect information through commonly used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (e.g., browser type, browser language), your internet Protocol (“IP”) address, and the actions you take on the Site (such as the webpages viewed, and the links clicked).
- Session cookies: a session cookie is only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
- Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
- First-party cookies: the function of a first-party cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between AAPL’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
- Third-party cookies: the function of a third-party cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the third party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
- Where strictly necessary: These cookies are essential to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance: These cookies collect information about how visitors use a Site (e.g., which pages visitors go to most often, if they get error messages from webpages). They also allow us to record and count the number of visitors to the Sites, all of which enables us to see how visitors use the Sites to improve the way that our Sites work. These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous.
- Functionality: These cookies allow our Sites to remember choices you make (e.g., your username, your language, region you are in) and provide enhanced features. For instance, a Site may be able to remember your login details, so that you do not have to repeatedly sign into your account when using a particular device to access our Site. These cookies can also be used to remember changes you have made to text size, font, and other parts of webpages that you can customize. They may also be used to provide services you have requested, such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.
- The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, AAPL’s Sites are not compatible with DNT.
Use of Web Beacons
- The Sites may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Sites and interaction with emails from AAPL. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve our Sites and email communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about AAPL and our services. We will conduct this review on an anonymous basis.
Use of IP Addresses
- When you visit our Sites, AAPL collects your IP addresses to track and aggregate non-Personal Information. For example, AAPL uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address.
DISCLOSURE OF INFORMATION TO OTHERS
Third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation, which purposes are as follows:
- To provide the products and services you have requested from us;
- To notify you or allow our affiliated companies to notify you of certain products or services offered by our affiliated companies;
- To process transactions through data processing service providers;
- If the information is a credit card number, to process credit card payments—through third-party payment processing, clearing, and settlement systems in association with various banks; and
- To fulfill joint marketing agreements.
If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent. Contact us on firstname.lastname@example.org for more information on these third parties.
In the normal course of performing services for our clients, Personal Information may be shared within AAPL and its affiliates for research and statistical purposes, system administration, and crime prevention or detection. When you supply us with information containing third-party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform general insurance and other services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information and the fact that it may be disclosed to third parties such as AAPL, and that they have consented to such disclosure and use.
Because the majority of the service providers we use are located in the United States, including certain AAPL affiliates, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under U.S. laws.
AAPL’s vendors/service suppliers are expected to provide the same protections regarding the collection, use, and retention of data as we do.
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. In addition, if either AAPL itself or substantially all AAPL assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances.
Other Legally Required Disclosures
AAPL preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site or other Products if AAPL has a good faith belief that such action is necessary to (1) protect and defend the rights, property or safety of AAPL, employees, or other users of its Sites, or the public; (2) enforce the terms and conditions that apply to use of the Sites; (3) comply with a legally valid request from a competent governmental authority; or (4) respond to claims that any content violates the rights of third parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request.
CALIFORNIA’S “SHINE THE LIGHT” LAW
California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third parties for direct marketing purposes for the preceding calendar year, as well as the addresses and names of such third parties. AAPL does not share any personal information collected from this site with third parties for their direct marketing purposes.
EUROPEAN UNION’S “GENERAL DATA PROTECTION REGULATION (GDPR)” LAW
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It also addresses the export of personal data outside the EU. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. In compliance of this law, AAPL does not utilize data for any reasons other than to fulfill commitments to existing products and services. AAPL does not sell any personal data or information collected from this site with third parties for their direct marketing purposes. AAPL has data retention and storage mechanisms in place to control who has access to the data and has placed limits on what purposes the data can be used for.
Your knowledge of and consent to AAPL’s collection, use, and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
- Your voluntary provision of Personal Information to us directly;
- Your express consent or acknowledgment contained within a written, verbal, or electronic application or claims process; and
- Your verbal consent solicited by AAPL (or our agent) for a specified purpose.
Where AAPL relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent, or holder of a power of attorney. Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. AAPL will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for AAPL to collect, use, or disclose your Personal Information could mean that we cannot obtain requested products, services or information for you.
If you wish to withdraw your consent, please refer to the “Questions or to Withdraw Consent” section below.
However, there are several instances in which AAPL does not require your consent to engage in the processing or disclosure of Personal Information. AAPL may not solicit your consent for the processing or transfer of Personal information for those purposes that have a statutory basis, such as in the following instances:
- The transfer or processing is necessary for the performance of a contract between you and AAPL (or one of its partners);
- The transfer or processing is necessary for the performance of a contract, concluded in your interest, between AAPL (or one of its affiliates) and a third party;
- The transfer or processing is necessary, or legally required, on important public interest grounds; for the establishment, exercise or defense of legal claims; or to protect your vital interests; or
- The transfer or processing is required by applicable law.
LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION
AAPL may collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose and, subject to your consent (where appropriate) that new purpose will become an Identified Purpose.
AAPL will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract or auditing requirements.
We have in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information we maintain. Safeguards will vary depending on the sensitivity, format, location, amount, distribution, and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties and similar security protocols. However, due to the nature of the internet and related technology, we cannot absolutely guarantee the security of Personal Information, and AAPL expressly disclaims any such obligation.
ACCURACY, ACCOUNTABILITY, OPENNESS, AND CUSTOMER ACCESS
Our knowing about changes to some of your Personal Information (e.g., email address) may be key to effectively communicating with you at your request. If any of your details change, update us by emailing email@example.com. Please keep us informed of changes to your Personal Information.
You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete or incorrect. However, to secure your Personal Information, AAPL does not provide online access to its customers to view or amend Personal Information in its database.
QUESTIONS OR TO WITHDRAW CONSENT
You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that AAPL provides to you) by either (1) making changes to your profile via our online portal or (2) writing or sending an email to us at the following address:
American Association of Private Lenders
7509 NW Tiffany Springs Pkwy, Ste 200
Kansas City, MO 64153
Tel: (913) 888-1250
We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.
Normally, we will respond to access requests within 7 business days.
Complaints can be directed to:
American Association of Private Lenders
7509 NW Tiffany Springs Pkwy, Ste 200
Kansas City, MO 64153
Tel: (913) 888-1250
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.
American Association of Private Lenders
7509 NW Tiffany Springs Parkway
Kansas City, MO 64153