July 2018 V1.2
PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
BICRA 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 Blockchain Industry Compliance and Regulation Association is committed to respecting and protecting your privacy as a research respondent who is participating in a study. This policy explains how BICRA collects and uses data that BICRA obtains via surveys and other primary research methods that BICRA uses. If you are participating in one of BICRA’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:
WHAT INFORMATION WE COLLECT
The information gathered by BICRA from this Site 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 this Site, you may choose to provide us with information to help us serve your needs. “Personal Information” or “PI” is information recorded in any form that identifies an individual or can be used to identify an individual. It includes 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 opinions and preferences.
You provide “PI” to the BICRA in the course of participating in research directly to the BICRA and utilizing BICRA products and services. In such cases, BICRA will comply with the contact limitations and data protections to which you agreed when you provided that permission. The BICRA may collect and use PI 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. BICRA uses these questions to help confirm that the research reflects a representative sample of the population the BICRA is studying. The BICRA also automatically collects information that is made available by the device you use to access BICRA’s website for system administration, surveys, service improvement, 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 “PI”, 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 of your personal data be destroyed. Wherever reasonable and practical, we will carry out such a request.
Below are some additional ways we collect data:
1. When you request content
2. When you register with us and/or join the BICRA as a member
3. When you submit content
4. When you submit a resume
Website Navigational Information
As you navigate the Site, 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 web pages viewed and the links clicked).
There are different kinds of cookies with different functions:
Use of Web Beacons
Use of IP Addresses
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:
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 email@example.com for more information on these third parties.
In the normal course of performing services for our clients, Personal Information may be shared within BICRA 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 BICRA, and that they have consented to such disclosure and use.
Because many of the service providers we use are located in the United States, including certain BICRA 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.
BICRA's service suppliers adhere to 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 BICRA itself or substantially all BICRA 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
BICRA preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site or other Products if BICRA has a good faith belief that such action is necessary to (1) protect and defend the rights, property, or safety of BICRA, employees, or other users of this Site or the public; (2) enforce the terms and conditions that apply to use of this Site; (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. BICRA 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, BICRA does not utilize data for any reasons other than to fulfill commitments to existing products and services. BICRA does not share any personal data or information collected from this site with third parties for their direct marketing purposes. The BICRA 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 BICRA’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:
Where BICRA 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. BICRA will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for BICRA to collect, use, or disclose your Personal Information could mean that we cannot obtain insurance coverage or other 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 BICRA does not require your consent to engage in the processing or disclosure of Personal Information. BICRA 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:
LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION
BICRA will 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.
BICRA 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 BICRA 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, you can update us by emailing us. 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, BICRA does not provide online access to its customers to view or amend Personal Information in its database.
Your Personal Information may also be stored, and can also be accessed, at the local BICRA chapter office with which you are a member.
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 BICRA 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:
Blockchain Industry Compliance and Regulation Association
61 Broadway, Suite 1105
New York, NY 10006
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 30 days.
Complaints can be directed to:
Blockchain Industry Compliance and Regulation Association
61 Broadway, Suite 1105
New York, NY 10006