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ork in progress as outlined in the OTA Online Trust Principles and submitted to the FTC .  This is a conceptual implementation reflecting OTA practices and may or may not be applicable to other businesses or sites.  A template will be created to include recommended content to consider and an explanation of what to include in each section.  Send comments to staff@otalliance.org.

See example with icons

Privacy & Data Collection Statement Summary (work in progress, revised Dec 24, 2009)
What is collected?
The Online Trust Alliance (OTA) may collect unidentified or anonymous information about your visit to the OTA site including your internet Protocol (IP) address of your computer, the date and time you visited, browser version, among other anonymous data points.  We also may actively collect other information for our email list subscriptions, such as your email address and company information.  OTA does not purchase or use any third party lists. No credit card data is captured or retained on any OTA servers.  When registering for OTA events, personal information including your name, contact information and related information is collected.  More Details>
Who do you share my data with?
No data is ever shared, exchanged or sold to any third party including OTA member companies or our vendors. Credit card data is encrypted and provided directly to third party credit card processors and merchant banks and is never stored or retained by OTA.  More Details>

Why is this data collected?
1. As part of OTA's mission, we publish resources, reports and guidelines free of charge. 
2. Information is collected to help improve the Site, analyze trends, and administer the Site. 
3. Data for OTA event registrations are retained for registration, billing, program evaluation and future OTA event communications.
4. Email newsletter subscriptions are mailed approximately once per month, and limited to news about OTA's initiatives, events, industry news, business trends and government issues.  More Details>

How long is the data retained?
1. Web usage and site traffic data is aggregated and retained for a period of 12 months. 
2. Email subscription data is retained as long as a subscriber maintains membership, and or the email does not bounce or rejected more than 3 times over a twelve month period or until a user unsubscribes.
3. Non-engaged subscribers, (subscribers who do not open or click on their email) may be removed by OTA from some or all lists which they have subscribed or signed up for.
More Details>
How does OTA help secure the data?
1. All data sent and received is transmitted over secure and encrypted connections.
2. All data storage and backup systems are encrypted.  
3. OTA maintains a 24/7 data loss and breach incident plan
4. Use of Extended Validation SSL Certificates (EV SSL) to help provide assurance the site and pages are legitimate. 
More Details>

How can I access my information and how do I opt-out?
No data is collected which can be attributed to an individual user.  You may access, update and correct the information OTA has captured and stored as a result of your opt-in to our email list.  If you have opted-in to our email list, you may opt-out by clicking on the unsubscribe link in the footer of all email or in the email unsubscribe header rendered by many email providers including Gmail and Hotmail.  Attendees of OTA events are automatically subscribed to the OTA Newsletter, but no profiling or data sharing is conducted.  More Details>

last updated: 9/22/09

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Online Trust Alliance, (OTA, Inc) is committed to protecting your privacy.  By accessing the Site, you are consenting to the information collection and use practices described in this privacy statement.

Collecting Your Personal Information
We will ask you when we need information that personally identifies you (personal information) or allows us to contact you to provide a service or carry out a transaction that you have requested such as requesting information about OTA, ordering e-mail newsletters, joining OTA, signing up for an event or training. The personal information we collect may include your name, title, company or organization name, work e-mail, work phone, work or home address, information about your job function, information about your company, and credit card information.
When you register for an event on our site you are asked for your name, email address and billing information (such as credit card number and expiration date).  Although the event registration page has the same look and feel as https://otalliance.org you may actually submitting registration information to our third party service provider who then shares the information back with https://otalliance.org in order to fulfill your event registration request.  Please note that our privacy statement does apply and that our service provider must treat your personal information in accordance with our privacy statement.   Your security is important to our third party service provider.  When you enter sensitive information (such as credit card number) on the event registration form, they encrypt that information using secure socket layer technology (SSL).

The Site may collect certain anonymous information about your visit, such as the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet; the date and time you access the Site; the pages that you access while at the Site and the Internet address of the Web site from which you linked directly to our site. This information is used to help improve the Site, analyze trends, and administer the Site.

Use of Your Personal Information
The personal information collected through our offline forms will be used to operate the Site and to provide the service(s) or carry out the transaction(s) you have requested or authorized.

In support of these uses, OTA may use personal information to provide you with more effective customer service, to improve the Site and any related OTA products or services.  We may use your personal information to provide you with important information about the product or service that you are using, including critical updates and notifications. OTA occasionally hires other companies, consultants and contractors to provide limited services on our behalf, such as Web site hosting, packaging, public relations, mailing and, answering customer questions about products and services, and sending information about our products, special offers, and other new services. We will only provide those companies the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using that information for any other purpose.   OTA may disclose personal information if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or comply with legal process served on OTA or the Site; (b) protect and defend the rights or property of OTA or (c) act in urgent circumstances to protect the personal safety of OTA employees or agents, users of OTA products or services, or members of the public.

Control of Your Personal Information
Except as otherwise described in this statement, personal information you provide on the Site will not be shared outside of OTA without your permission.

Access to Your Personal Information
You can review and edit the personal information and any contact preferences provided at the Site by sending e-mail to staff@otalliance.org or in writing to:

Online Trust Alliance (OTA)
9057 Points Drive NE
Clyde Hill WA, 98004-1611

Security of Your Personal Information
OTA is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. For example, we store the personal information you provide on computer servers with limited access that are located in controlled facilities. Additionally, we use Secure Socket Layer (SSL) protocol and Extended Validation SSL Certificates on our site to help ensure safety of the information being transmitted while logged into your Membership account.

We use both session ID and persistent cookies.  We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our site including access to our member’s only area.   We do not link the information we store in cookies to any personally identifiable information you submit while on our site.

The use of cookies by our partners or service providers is not covered by our privacy statement.  We do not have access or control over these cookies.  Our partners and service providers may utilize session ID cookies to make it easier for you to navigate our site, in order for you to register for events, pay membership dues, etc.

Changes to This Privacy Statement
We may occasionally update this privacy statement. When we do, we will also revise the "last updated" date at the top of the privacy statement. For material changes to this privacy statement, we will notify you either by placing a prominent notice on the home page of our web site or by directly sending you a notification. We encourage you to periodically review this privacy statement to stay informed about how we are helping to protect the personal information we collect. Your continued use of the service constitutes your agreement to this privacy statement and any updates.

Contact Information
OTA welcomes your comments regarding this privacy statement. If you believe that OTA has not adhered to this privacy statement, please contact us by e-mail at staff@otalliance.org or via postal mail at the address provided below, and we will use commercially reasonable efforts to promptly determine and remedy the problem.

Online Trust Alliance (OTA)
PO Box 803
Bellevue, WA 98009-803
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at staff@otalliance.org  or you may contact us at our address above or by phone at 425-985-1421.  

Online Trust Alliance (OTA) is a licensee of the TRUSTe Privacy Program.  TRUSTe is an independent, organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices.  This privacy statement covers the Web site https://otalliance.org.  Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.   If you have questions or concerns regarding this statement, you should first contact the Privacy Officer at staff@otalliance.org.  If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php.   TRUSTe will then serve as a liaison with us to resolve your concerns.