The Empty Lot Privacy Policy

Effective Date: February 14, 2021

The Empty Lot LLC (referenced herein as
“we,” “us,” “The Empty Lot,” or “our”) has developed this policy statement to
assist end users (referenced herein as “you,” “user,” or “your”) of the
websites and/or digital properties owned and operated by The Empty Lot including
but not limited to all sites associated with theemptylot.com, digital and physical platforms for The Empty Lot events, and The Empty Lot online store in understanding why we collect personally identifiable
information (the “Privacy Policy”). The following Privacy Policy
summarizes the personally identifiable information gathering and use
practices for all websites and/or digital properties owned and operated
by The Empty Lot (as referenced herein as the
“Website”).

The Empty Lot reserves the right to change this Privacy Policy at any
time to address changes to its platforms, information collection, disclosure, or
use practices or changes in law. If The Empty Lot makes changes to this Privacy
Policy, we will post those changes at this location so you are aware of what information we
collect, how we use it, and under what circumstances, if any, we
disclose it. We encourage you to review this Privacy Policy on a
periodic basis.

1. Collected Information.
   
   Technical Information is gathered automatically. When you browse our
   Website, you do so anonymously. We
   gather technical information including, but not limited to, browser
   type, IP address, pages visited and other activities on the Website,
   device type, and time and date of visit for analytical purposes. We may use cookies or similar
   technology to collect such information for similar and other
   purposes. See the Digital Advertising & Analytics section of this
   Privacy Policy to learn more about the use of this information and the
   choices available to you.
   
   Personal Information is what you provide to
   us. On various pages of the Website, you have an opportunity to
   provide information to us about yourself, such as your name and email address. You provide this information when you register with the
   Website or send a message on the Website. In addition, when you register
   on our Website or send a message on the Website, your personally
   identifiable information, including your email, will be added to our
   customer database and distribution list. You may make changes to your
   preferences on www.td.org by signing in, navigating to My Account, and
   selecting “Communications Preferences.”
   
   Financial Information: ATD collects credit or debit card information to facilitate a transaction.
   
   In addition, ATD may supplement the personally identifiable information
   collected from you with information from other sources, such as
   publicly available databases or other information from business
   partners, in order to enhance ATD’s ability to provide or advertise its
   services or those of other entities or to otherwise tailor, manage, or
   operate the Website.
   The provision of information is sometimes
   required by law and at other times is a result of a contractual
   requirement. You may be required to provide information, for example in a
   case where we sign a contract with you, and the non-provision of
   information could, in certain circumstances, prevent a transaction from
   concluding.




2. Use of Information. Below,
   ATD sets forth more detail on how ATD uses your information. Personal
   and Contact Information: ATD uses your personal information to operate
   the Website and, in particular, facilitate the education, interactive
   community and networking capabilities of the Website, advertise its
   services and the goods and services of its members and third parties,
   create a personalized experience for you, provide you with news,
   articles, and information, for internal business purposes, to contact
   you regarding a survey, get in touch with you when necessary with
   respect to transactions conducted through the Website, material changes
   in the Website’s policies and agreements, new products, events, tools,
   offerings, or services ATD may offer, or otherwise. Refer to Section 10
   (“Your Choices”) within this privacy policy for information on selecting
   your preferences or opting out of receiving communications.
   
   Demographic Information: ATD shares demographic data on an aggregated
   basis, which will not identify any particular user, with ATD’s members,
   partners and affiliates and for advertising or other technical or
   business purposes.
   
   Financial Information: ATD will use financial information to fulfill your transaction or order.
   
   Survey Results: ATD uses survey results for business or marketing
   purposes or as may be required by law, and to participate in government
   programs and initiatives.
   
   Technical Information: ATD will use
   this information to facilitate educational opportunities, provide
   content, participation, or otherwise allow access to or use of certain
   information, tools, or features and for improving the Website’s
   performance, usability, and design. ATD also uses technical information
   to help diagnose problems with ATD’s servers, analyze Website usage
   trends, track user movements on the Website, and to otherwise manage and
   monitor the Website.
   
   Where we intend to process your personal
   data for a purpose other than the purpose for which it was collected,
   we will provide you with information regarding the purpose for the
   processing, as well as other relevant information, prior to processing
   your personal data for the new purpose.
   




3. Disclosure of Information. We may share personally identifiable information with third parties, including the following:
   
   • Affiliated third parties and partners such as ATD advertisers, sponsors, or suppliers;
   • Third parties that perform services on our
     behalf, such as for website operation, the ATD learning portal, the ATD
     Job Bank, marketing, and transaction fulfillment purposes;
   • ATD members through the ATD member directory on the website;
   • Third parties for their direct marketing purposes;
   • As part of a corporate sale, merger, or
     acquisition, or other transfer of all or part of our assets including as
     part of a bankruptcy proceeding. In the event a transaction of this
     kind occurs that results in the transfer of personally identifiable
     information, ATD will notify you via e-mail and/or place a prominent
     notice on the Website for 30 days of any such change in ownership or
     control and the possible changes to this Privacy Policy;
   • To protect against misuse or unauthorized
     use of the Website or as is otherwise required to limit legal liability,
     protect or defend ATD’s rights, property, or interests, or protect the
     safety, rights, or property of ATD’s users;
   • When legally required to do so in accordance with government requests or regulations or legal proceedings; or
   • With your consent or as otherwise disclosed at the time of data collection or sharing.

   The Website may also allow you to create a customer or
   member profile (“Profile”) and participate in Online Communities. You
   have choices about the information you include in your Profile, such as
   your job title and photograph. ATD wishes to remind you that any
   information you disclose in your Profile or in a communication forum,
   including any personally identifiable information, could become public
   information and visible to all ATD members. You may opt out of making
   such information public by logging into www.td.org and adjusting the
   privacy settings of your Profile.

   We may share information that
   has been de-identified or aggregated without limitation, including with
   our business partners, members, and affiliates and/or the general
   public, the news media, and with the U.S. Government and state
   governments.

4. International Visitors. This section applies to those that visit all ATD digital properties from the European Economic Area and Switzerland.

   Lawful Basis for Processing

   On
   certain occasions, we process your personal data when it is necessary
   for the performance of a contract to which you are a party, such as to
   provide services to you. We may also process your personal data to
   respond to your inquiries concerning our products and services.

   On
   other occasions, we process your personal data where required by law.
   We may also process your personal data if necessary to protect your
   interests or the interests of a third party.

   Additionally, we
   process your personal data when necessary to do so for direct marketing
   purposes, to help you find content or information that you are seeking,
   to complete a transaction, to deliver a service, or for a related
   reason, and these interests are not overridden by your data protection
   rights. Where we process your personal data for these purposes, our
   legitimate interest is to serve the needs of ATD members and customers
   and carry out our business operations.

   If the processing of
   personal data is necessary and there is no statutory basis for such
   processing, we will ask for your consent to process your personal data.
   You have the right to withdraw your consent to processing of personal
   data at any time.

   If you wish to exercise the right to withdraw
   consent, contact our Director of Communications. Visit the Contacting Us
   section below for contact information.

   Transfers of Personal Data

   Please
   be aware that the personal data we collect may be transferred to and
   maintained on servers or databases located outside your state, province,
   country, or other jurisdiction, where the privacy laws may not be as
   protective as those in your location. If you are located outside of the
   United States, please be advised that we process and store personal data
   in the United States and your consent to this privacy policy represents
   your agreement to this processing.

   Your Rights
   You have a right to the following:

   • To request access to the personal data we hold about you;
   • To request that we rectify or erase your personal data;
   • To request that we restrict or block the processing of your personal data;
   • Under certain circumstances, to receive
     personal data about you that we store and transmit to another without
     hindrance from us, including requesting that we provide your personal
     data directly to another, i.e., a right to data portability; and
   • Where we previously obtained your consent, to withdraw consent to processing your personal data.

   To exercise these rights, contact our Director of
   Communications. See the Contacting Us section below. Please be aware
   that ATD may be unable to afford these rights to you under certain
   circumstances, such as if we are legally prevented from doing so.

   Additionally,
   you have the right to lodge a complaint against us. To do so, contact
   the supervisory authority in your country of residence.

5. Retention. We will process and store
   your information only for the period necessary to achieve the purpose of
   the storage, or as permitted by law. The criteria used to determine the
   period of storage of information is the respective statutory retention
   period. ATD will retain data for seven years following a financial
   transaction and five years for other engagement or interaction with ATD.
   After expiration of that period, the corresponding information is
   routinely deleted, as long as it is no longer necessary for the
   fulfillment of a contract or the initiation of a contract.




6. Cookies & Computer-Related Information. Please see ATD’s Cookie Policy here.




7. External or Third-Party Websites. To
   the extent hyperlinks or gateways (whether through banner advertisements
   or otherwise) are utilized to access external or third-party sites, you
   should be aware that these external or third-party sites may collect
   personally identifiable information and are not controlled by ATD and
   therefore, are not subject to this Privacy Policy. ATD suggests that you
   check the privacy policies of these sites to determine how the
   proprietors of these third-party sites will utilize your personally
   identifiable information.

   The Website may also include integrated
   social media tools or plug-ins, such as social networking tools offered
   by third parties. If you use these tools to share personal information
   or you otherwise interact with these features on the Website, those
   companies may collect information about you and may use and share such
   information in accordance with your account settings, including by
   sharing such information with the general public. Your interactions with
   third-party companies and your use of their features are governed by
   the privacy notices of the companies that provide those features. We
   encourage you to carefully read the privacy notices of any accounts you
   create and use.

8. Collection of Information by Third-Party Websites.
   We sometimes may offer content (e.g., promotions) that is sponsored by
   or co-branded with an identified third party. In these instances, the
   third party may obtain information that you voluntarily submit to
   participate in a Website activity. We have no control over the third
   party’s use of this information. The Website will notify you at the time
   of information collection if a third party will obtain such
   information.




9. Digital Advertising & Analytics.
   We may work with third parties that collect data about your use of the
   Website and other sites or apps over time for non-advertising purposes.
   ATD uses Google Analytics and other third-party services to improve the
   performance of the Website and for analytics and marketing purposes. For
   more information about how Google Analytics collects and uses data when
   you use our Site, visit https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.




10. Your Choices. We may use the
    personally identifiable information we collect from you to offer you
    products and services that may be of interest to you. ATD makes its
    customer, conference attendee, and some webcast registrant lists
    available to other reputable organizations whose products or offerings
    may be of interest to the ATD community. If you would like to opt out of
    receiving these materials (electronic or hard copy), you may contact
    ATD Customer Care by email at customercare@td.org
    or by following the unsubscribe instructions of the communication
    received. Additionally, you may select the content and offerings you
    wish to receive. To select your preferences, see the My Account section
    of www.td.org and Communications Preferences.

    Please note:
    regardless of the email preferences selected, all new and renewing ATD
    members will receive an order confirmation for their membership and a
    welcome and orientation email series explaining how to access
    member-only benefits and content.

11. California Privacy Rights. California
    Civil Code Section 1798.83 permits users of the Website who are
    California residents to, not more than once per calendar year, request
    certain information regarding our disclosure of personal information to
    third parties for such third parties’ direct marketing purposes. To make
    such a request, please write to us at the address below.




12. Updating Your Information. You may request to review, change, or update your contact information by visiting this link: https://emailprofile.td.org (if you have an ATD account, please log in).




13. Contacting Us. Comments or questions
    can be directed to the Association for Talent Development, in our role
    as data controller, by using our contact information. You may contact us
    at:

    Association for Talent Development
    Attention: Director of Communications
    1640 King Street
    Alexandria, VA 22314
    703.683.8100
    customercare@td.org