Effective November 9, 2022
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Acknowledgement and Consent
Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).
Applicability & Eligibility
Eligibility To Use The Services. The Services are not directed to children under the age of 16. You may not use the Services if you are under the age of 16. We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 16 or knowingly allow such persons to register for or use our Services. In the event that we learn that we have collected Personal Information from a child under age 16 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database.
How We Collect Personal Information and from What Sources
Information You Provide Us. The Personal Information we collect through our Website, or from our business partners, service providers, exhibitors, and sponsors and may include the following:
Information Collection & Use
Commodity Classic collects data about you and your use of the Services through various means, including when you provide information to us such as when you join, sign up for a membership, donate, register for events and webinars including The Commodity Classic Show®, and when we automatically collect information about you when you access, use, or interact with the Services. We use this information for a variety of different reasons, including to improve the Services and to tailor the Services to you.
Commodity Classic processes Personal Information collected through the Services on the lawful basis of legitimate interests to provide the Services to you. Such processing is necessary for the purposes of the legitimate interests pursued by Commodity Classic or by our Service Providers related to the Services.
We collect several categories of Personal Information from and about you as summarized in the following table:
Commodity Classic Membership & Event Information. Commodity Classic collects certain Personal Information from you when you join Commodity Classic or register for Commodity Classic events. Commodity Classic uses this information to provide your membership, register you for events, provide information about memberships and events, and administer your registrations with Commodity Classic.
Location Analytics. Our mobile application includes functionality which allows our attendees to identify their location at the event, in certain cases. Application users choose to use the application anonymously or to login as an identified user, in which case the Personal Information provided upon registration may be used. Information such as IP address, device ID and location is gathered.
Commodity Classic Account Information. Commodity Classic may require you to register for an account (a “Commodity Classic Account”) in order to use certain Services. We do not require you to register to use all of our Services. However if you do register for Services offering an Commodity Classic Account, you will gain access to those areas and features of the Services that require registration. Commodity Classic will collect certain information about you in connection with your registration for your Commodity Classic Account, which may include Personal Information and other information such as a username, password, personal profile, pictures, your location, and information about your contacts. Some of your Commodity Classic Account information may be displayed publicly. You are not required to provide your Personal Information; however, if you choose to withhold certain Personal Information, we may not be able to provide you with certain Services.
Payment Transaction Information. We may collect and store information related to purchases and donations made through the Services. You may provide to our service providers certain information to complete payments via the Services, including your credit or debit card number, card expiration date, CVV code, and billing address (collectively, “Payment Information”), along with your name and billing, delivery and shipping address, to complete payment transactions through certain Services. Please note Commodity Classic works with Service Providers (as defined below) to handle payment transactions. Commodity Classic does not itself collect or retain your credit card or other financial account information. You are subject to the privacy policies and terms and conditions of our Service Providers when purchasing a Commodity Classic membership, shopping for Commodity Classic products, or making donations, the terms of which may differ from those of Commodity Classic for the Commodity Classic Services. Please review the Service Providers’ privacy policies and terms and conditions before using their services.
Form Information. We may use online forms to request certain information from you in order to perform certain Services, such as your location to assist you in locating our products, or your contact information to assist with contacts or service requests. This information may include Personal Information.
Correspondence Information. If you sign up for a membership, attend a conference or event including The Commodity Classic Show®, email us, subscribe to our newsletters mailing lists, publications, or blogs, we may keep your message, email address, and contact information to respond to your requests, provide the requested products or Services, and to provide notifications or other correspondences to you. If you do not want to receive email from us in the future, you may let us know by sending us an email or by writing to us at the address below. Please note requests to remove your email address from our lists may take some time to fulfill. We may still contact you including via email as needed to provide important announcements or notifications regarding the Services.
Support Information. You may provide information to us via a support request submitted through the Services. We will use this information to assist you with your support request and may maintain this information to assist you or other Users with support requests. Please do not submit any information to us via a support submission, including confidential or sensitive information that you do not wish for Commodity Classic or our Service Providers to have access to or use in the future.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including the following:
Behavioral Tracking. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services, or associate Personal Information with other information collected in this manner.
Keystrokes. We or our service providers may keep track of and/or collect the keystrokes and cursor movements of Website visitors before purchase of a Product or Service from our Website (and before we have any email address or other information about you (other than IP address) which would specifically identify you), but, this information is anonymous and, at the time of collection, we do not directly associate or attempt to associate this information with you as an identifiable individual. If you sign up to receive our emails (e.g., through the popup box that appears) we then do have the ability going forward to associate the keystroke and cursor information with the email address you provide. We use this information solely for the purpose of improving our Website to improve our customers’ user experience (e.g., improving navigation, readability, etc.).
The information we collect automatically is statistical data and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Products and Services, including, but not limited to, by enabling us to: estimate our audience/visitor size and usage patterns, store information about your preferences, allowing us to customize and improve our Website, speed up your searches, and/or, recognize you when you return to our Website.
Cookies, Web Beacons, Links, And Other Tracking Technologies
Unique Identifiers. When you use or access the Services, we may access, collect, monitor, store on your device, and/or remotely store one or more “Unique Identifiers,” such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Services. Some features of the Services may not function properly if use or availability of Unique Identifiers is impaired or disabled.
Log File Information. When you use our Services, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Services, for example, when you visit our websites, sign into our Services, or interact with our email notifications. Commodity Classic uses log file data to provide, understand, and improve our Services, and to customize the content we show you. Commodity Classic may link this log file to other information Commodity Classic collects about you via the Services.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:
We may disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more of the following purposes:
Service Providers. Commodity Classic works with various organizations and individuals to help provide the Services to you (“Service Providers“), such as website and data hosting companies and companies providing analytics information, like Google Analytics (see below for additional information). We may share your Personal Information with our Service Providers for the purpose of providing the Services. The information we share to our Service Providers may include both information you provide to us and information we collect about you, including Personal Information and information from data collection tools like cookies, web beacons, log files, Unique Identifiers, and location data. Commodity Classic takes reasonable steps to ensure that our Service Providers are obligated to reasonably protect your information on Commodity Classic’s behalf. If Commodity Classic becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.
Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. More information on how to opt-out of third-party advertiser tracking mechanisms here.
Google Tools. We use tools provided by Google as described below.
We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website.
Google reCAPTCHA. We use Google reCAPTCHA, which identifies bots by collecting hardware and software information and sending that data to Google for analysis. More about Google reCAPTCHA is available here.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.
Event-Related Disclosure. From time to time, we may conduct events, run contests, make special offers, or other activities (“Events”), possibly together with an exhibitor, sponsor or other Service Provider. If you provide information to such third parties, you give them permission to use it for the purpose of that Event and any other use to which you consent. We cannot control such third parties’ use of your information. If you do not want your information to be collected by or shared with such third parties, you can choose not to participate in these Events.
We may share your Personal Information with exhibitors for their marketing and commercial purposes (including, but not limited to, their sending you marketing and related communications), but only if you have both registered for a conference and either had your attendee credentials scanned by the exhibitor at its booth or enter an exhibitor’s booth virtually online (this does not apply to casual website visitors or conference attendees who are not registered to enter the exhibit hall).
Disclosure of De-Identified Personal Information. We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose.
Your Consent to Disclosure/Transfer/Sale of Your Personal Information. You consent to our disclosure of your Personal Information, De-Identified Personal Information, and other information you provide to us (collectively, “Transferred Information”) to a potential or actual buyer or acquirer of our company or other successor for the purpose of considering or undergoing a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) as part of a Transfer, of any or all of our rights, in whole or in part, in or to Transferred Information and your consents, with or without notice to you and without your further consent. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By providing any Personal Information, you expressly agree and consent to the use and/or transfer of Transferred Information or other information in connection with a Transfer. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.
We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.
Access To The Information Commodity Classic Has Collected About You
Commodity Classic provides certain tools and settings within the Services to help you access, correct, delete, or modify your Personal Information associated with the Services. Commodity Classic welcomes you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Services uses of your information, or to withdraw any consent you may have granted to Commodity Classic.
Please note requests to delete or remove your information do not necessarily ensure complete or comprehensive removal of the content or information posted, and removed information may persist in backup copies indefinitely. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Services, may no longer be available to you.
We may store the information we collect about you indefinitely, or as otherwise required by law. Following termination or deactivation of a Commodity Classic Account, Commodity Classic may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.
Do Not Track. Commodity Classic does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including Personal Information, about your online activities over time and across different websites or online services when you use Services. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
Security Of Your Information. Commodity Classic takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration and destruction. Commodity Classic implements security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, Commodity Classic cannot guarantee the security of our systems or databases, nor can we guarantee that Personal Information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Services is provided at your own risk.
Please do your part to help us keep your information secure. You are responsible for maintaining the confidentiality of your password and Commodity Classic Account, and are fully responsible for all activities that occur under your password or Commodity Classic Account. Commodity Classic specifically reserves the right to terminate your access to the Services and any contract you have with Commodity Classic related to the Services in the event it learns or suspects you have disclosed your Commodity Classic Account or password information to an unauthorized third party. You hereby release and forever discharge us and our affiliates, subsidiaries, officers, directors, employees, and agents, and their respective successors and assigns, and you will indemnify, defend and hold us harmless, from and against any liability, claim, or cost (including attorneys’ fees), arising directly or indirectly from any failure by you to maintain the security of your email or other accounts that directly or indirectly results in an unauthorized third party having access to such email or accounts or causes us to transfer funds based on instructions purporting to have originated from you (i.e., “wire transfer fraud” or “business email compromise” events).
Additional Provisions Regarding The Services & Your Information
Commodity Classic shares your data, including Personal Information, with our website hosting Service Provider for the purposes of processing your data pursuant to your use of the Services.
Commodity Classic shares your data, including Personal Information, with our website hosting Service Provider for the purposes of processing your data pursuant to your use of the Services.
Safely Using Commodity Classic’s Services
Despite Commodity Classic’s safety and privacy controls, we cannot guarantee the Services are entirely free of illegal, offensive, pornographic, or otherwise inappropriate material, or that you will not encounter inappropriate or illegal conduct from other Users when using the Services. You can help Commodity Classic by notifying us of any unwelcome contact by contacting us using the information below.
The time period for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as your account is active, or as long as you are a registered member or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.
We may retain De-Identified Personal Information for as long as we deem appropriate.
Your California Privacy Rights
Under California Civil Code Section 1798.83 (known as the “Shine the Light” law), Commodity Classic members and customers who are residents of California may request certain information about our disclosure of Personal Information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Notices; Opting Out
By providing us with your email address (including by “following”, “liking”, linking your account to our Website or Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding our Products, Services, the Website, your Personal Information, or any aspect of our relationship, to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails. Please note that if you have opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them.
Where We Process and Store Personal Information
We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. You consent to our and our service providers’ transmission and/or transfer of your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.
If you are a resident or citizen of the UK, European Economic Area (“EEA”), or Switzerland, please see the section below on GDPR compliance.
If you are a citizen or resident of the UK, EEA, Switzerland, or other regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. We may do so to process your information by staff operating outside the these countries who work for us or for one of our service providers.
If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, processing, transferring, and storing your Personal Information out of the country in which you reside.
GDPR: The Follow Provisions Apply Only to Citizens and Residents of the United Kingdom, EEA, and Switzerland
We provide adequate protection for the transfer of Personal Information to countries outside of the UK, EEA, or Switzerland through a series of intercompany agreements based on or incorporating the Standard Contractual Clauses, or we rely on the European Commission’s adequacy decisions about certain countries, as applicable, and/or obtain your consent for these data transfers from Europe to the United States to other countries. We also may need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the UK, EEA, or Switzerland, or if you use our services and products while visiting countries outside this area.
Our Legal Basis for Processing Personal Information (UK, EEA, and Swiss Visitors Only)
If you are a visitor using our Website from the UK, EEA, or Switzerland, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we need the Personal Information to perform Services for you for which you have contracted with us, or where the processing is in our legitimate interests or rely upon your consent where we are legally required to do so and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we also may have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.
The collection and processing of your Personal Information may be necessary for the purposes of our legitimate interests. Such legitimate interest purposes may include:
Your Data Rights Under GDPR
If you are subject to GDPR, your rights include the following:
Contact Commodity Classic
Data Protection Officer
632 Cepi Drive, Chesterfield, MO 63005