Privacy Policy

PRIVACY POLICY

This Privacy Shield Policy (“Policy”) applies to all personal information received by Advertising Management Institute, Inc. (“Advertising Management Institute”, “we”, “our”, or “us”) in the United States from the European Economic Area (EEA) (which includes the member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland. This Policy also applies to all personal information previously received under the U.S.-EU Safe Harbor Framework and still held by Advertising Management Institute. This Policy sets out our practices for collecting, using, maintaining, protecting and disclosing that personal information.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Advertising Management Institute or to which Advertising Management Institute discloses personal information for use on Advertising Management Institute’ behalf. “Advertising Management Institute” means Advertising Management Institute, Inc., Advertising Management Institute Franchising Group, Inc., and any predecessors and successors in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of Advertising Management Institute to identify (together with other information) a living individual. Personal information does not include information that is anonymized or aggregated.

“Sensitive information” means any personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information that concerns health or sex life, and information about criminal or administrative proceedings and sanctions.

EU-U.S. PRIVACY SHIELD

Advertising Management Institute participates in and complies with the EU-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Advertising Management Institute has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability, which are the basis for the principles of this Policy. If there is any conflict between this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Advertising Management Institute’ certification, please visit https://www.privacyshield.gov/.

U.S.-SWISS SAFE HARBOR

Advertising Management Institute complies with the U.S.-Swiss Safe Harbor Framework (“Safe Harbor”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Advertising Management Institute has certified that it adheres to the Safe Harbor Privacy Principles of Notice, Choice, Onward Transfers, Security, Data Integrity, Access, and Enforcement, which are the basis for the principles of this Policy. If there is any conflict between this Policy and the Safe Harbor Principles, the Safe Harbor Principles shall govern. To learn more about the U.S.-Swiss Safe Harbor, and to view Advertising Management Institute’ certification, please visit http://www.export.gov/safeharbor.

PRINCIPLES

Notice

Advertising Management Institute receives personal information about individuals in the EEA and Switzerland collected by Advertising Management Institute and its franchisees. This personal information may include basic contact information like name and email address, billing information, and courses and training taken by students.

Advertising Management Institute uses this information to provide our educational and training-related services to franchisees, customer support for such services, to bill customers, and to correspond with customers. This information also facilitates our affiliates’ and franchisees’ services.

Advertising Management Institute also receives information about employees of Advertising Management Institute who are located in the European Union, and which is transferred in the context of the employment relationship. Advertising Management Institute uses this information for internal employment and human resources purposes. Advertising Management Institute commits to cooperate in investigations by and to comply with the advice of competent EU authorities.

Advertising Management Institute will subject all personal information received via the Privacy Shield and U.S.-Swiss Safe Harbor Framework to their respective Privacy Principles.

Advertising Management Institute is subject to the investigative and enforcement authority of the Federal Trade Commission (FTC), is obliged to disclose personal information in response to lawful requests by public authorities, for law enforcement, and national security purposes, and has potential liability for onward transfers to third parties.

Additionally, an individual may be allowed to invoke binding arbitration to resolve disputes under certain limited conditions.

Choice

Advertising Management Institute will offer individuals the opportunity to choose whether their information is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at the address given below. Advertising Management Institute does not disclose personal information to non-agent third parties. If this changes, Advertising Management Institute will offer an opt-out to individuals. Advertising Management Institute will not use sensitive personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Advertising Management Institute has received the individual’s affirmative and explicit consent (opt-in). Advertising Management Institute will treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.

Data Integrity

Advertising Management Institute will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Advertising Management Institute will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

Transfers to Agents

Advertising Management Institute contracts with third parties who perform business functions on our behalf. Advertising Management Institute uses these third parties to manage its IT system infrastructure, provide live, online support to customers, and to manage email lists. These entities may have access to personal information if needed to perform their functions for Advertising Management Institute. Advertising Management Institute does not disclose personal information to non-agent third parties.

For information received under the Privacy Shield, Advertising Management Institute will require its agents to safeguard personal information consistent with this Policy by contract, obligating the agent to provide at least the same level of protection as is required by the Privacy Shield Principles.

Under certain circumstances, Advertising Management Institute may bear liability for onward transfers of personal data where its agent processes personal data inconsistent with the Privacy Shield Principles, unless Advertising Management Institute proves that it is not responsible for the event giving rise to the damage.

For information received under the U.S.-Swiss Safe Harbor, Advertising Management Institute will obtain appropriate assurances from its agents that they will safeguard personal information consistent with this Policy. Examples of appropriate assurances that may be provided by agents include the following: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Privacy Shield and U.S.-Swiss Safe Harbor Principles, the Swiss Federal Act on Data Protection, its own Privacy Shield or Safe Harbor certification, or another European Commission or Swiss FDPIC adequacy finding.

Access and Correction

Upon request, Advertising Management Institute will grant individuals reasonable access to personal information that it holds about them. In addition, Advertising Management Institute will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. An individual may request to access their information, or otherwise correct, amend, or delete their information by contacting us at the address given below.

Security

Advertising Management Institute will take reasonable and appropriate precautions to protect personal information in its possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Enforcement

Advertising Management Institute will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Advertising Management Institute determines is in violation of this policy will be subject to disciplinary action. Advertising Management Institute is subject to the investigative and enforcement authority of the FTC.

Dispute Resolution—Privacy Shield

In compliance with the Privacy Shield, Advertising Management Institute commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with inquiries or complaints regarding this Policy should first contact Advertising Management Institute at the address given below. Advertising Management Institute will investigate and attempt to resolve complaints regarding use and disclosure of personal information by reference to the principles contained in this Policy.

Advertising Management Institute commits to cooperating with European Data Protection Authorities (“DPAs”).

Advertising Management Institute has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to the International Centre for Dispute Resolution (“ICDR”), the international division of the American Arbitration Association (“AAA”), a non-profit alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the ICDR website at http://info.adr.org/safeharbor for more information and to file a complaint. Under certain limited conditions, an individual may be able to invoke binding arbitration as provided under the Privacy Shield to address an otherwise unresolved complaint.

Dispute Resolution—U.S.-Swiss Safe Harbor

In compliance with the U.S.-Swiss Safe Harbor Principles, Advertising Management Institute commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this Policy should first contact Advertising Management Institute at the address given below. Advertising Management Institute will investigate and attempt to resolve complaints regarding use and disclosure of personal information by reference to the principles contained in this Policy.

Advertising Management Institute has further committed to refer unresolved privacy complaints under the U.S.-Swiss Safe Harbor Principles to the ICDR/AAA. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the ICDR website at http://info.adr.org/safeharbor for more information and to file a complaint.

CONTACT INFORMATION

Questions regarding this Policy should be submitted to Advertising Management Institute by mail to:

Privacy Liaison
Advertising Management Institute, Inc.
50 Public Square, Suite #200
Cleveland, OH 44113
+1 (216) 800-5887
Or by e-mail to contact@advertisingmanagementinstitute.org

LIMITATIONS & CHANGES

We may also be required to disclose an individual’s personal information in response to a lawful request by public authorities or in connection with a legal obligation. Adherence by Advertising Management Institute to these Privacy Shield and Safe Harbor Principles may also be limited to the extent necessary to meet national security, public interest or law enforcement obligations, and to the extent expressly permitted by an applicable law, rule or regulation. This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield and Safe Harbor Principles. The amended Policy will be made publicly available via Advertising Management Institute’ website.

Effective Date: 01/01/2017