1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct organizational communications. You can access the privacy controls via https://go.fdli.org/UnsubscribePage.html.
1.4 In this policy, “we”, “us” and “our” refer to the Food and Drug Law Institute (FDLI).
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, professional interests and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.5 We may process information contained in any inquiry you submit to us (“inquiry data“). The inquiry data may be processed for the purposes of offering educational programs and resources to you. The legal basis for this processing is monitoring and improving our website and services.
2.6 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased educational programs and resources and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.12 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We do not sell or exchange your personal data with third parties.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose your personal information with the organization we have on file as your employer for the purposes of verification.
3.4 Financial transactions relating to our website and services are handled by our payment services provider, PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.paypal.com/us/webapps/mpp/payflow-payment-gateway.
3.6 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.7 This Section 3.7 applies to you if you are an individual located in the European Union and FDLI processes your personal data in connection with offering goods or services within the European Union. If we intend to transfer your data to an organization outside of the European Economic Area (EEA), we will ensure that the data is afforded an adequate level of protection. If we intend to transfer your personal data for purposes other than those already stated in this policy to an organization outside of the EEA, we will notify you before doing so.
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are aware of any changes to this policy.
5.3 We may notify you of significant changes to this policy by email.
6. About cookies
6.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
6.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
6.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
7. Cookies that we use
8. Cookies used by our service providers
9. Managing cookies
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
9.2 Blocking all cookies will have a negative impact upon the usability of many websites.
9.3 If you block cookies, you will not be able to use all the features on our website.
10. Your rights
10.1 If you are individual in the European Union and FDLI processes your personal data in connection with offering goods or services within the European Union, you have certain rights to your personal data, contained in this Section 10.
10.2 Right of access. You can request an electronic copy of your personal data contained within our system.
10.3 Right to rectification. If your personal data is inaccurate or incomplete, you are entitled to have it updated or completed.
10.4 Right to erasure. You may ask us to delete or remove your personal data in certain circumstances.
10.5 Right to restrict or object to processing. You may ask us to restrict or block the processing of your personal data in certain circumstances, or request no contact from us.
10.6 Right to data portability. You have the right to obtain your personal data from us that is contained in our system for transfer to a third party, in certain circumstances.
10.7 Right to withdraw consent. If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.
10.8 In order to make a request to exercise any of these rights, please contact us by email, at [email protected].
10.9 If you have a concern about our privacy practices, including the way we have handled your personal data, you can report it to the data protection authority that is authorized to hear those concerns. The relevant authority is the data protection authority in your country of residence, the country where you work, or the country in which the alleged unlawful use of your personal data occurred.
11. Our details
11.1 This website is owned and operated by the Food and Drug Law Institute (FDLI).
11.2 Our principal place of business is at 1155 15th Street NW, Suite 910 Washington, DC 20005.
11.3 You can contact us:
(a) by mail, using the postal address given above;
(b) by telephone, at 202-371-1420; or
(d) by email, at [email protected].