Posting Date: 03/29/2019
Effective Date: 04/29/2019

The Florida Bankers Association (the “FBA”) has adopted the following privacy policy to help ensure your personal data is protected. 
This Privacy Policy applies to the websites, online services and mobile applications owned or controlled by the FBA (the "Sites"). This Privacy Policy applies to all users who access or use the Sites. By accessing or using the Sites, you agree to be bound by this Privacy Policy.
1. Information We Collect About You
The FBA collects: (i) personal data voluntarily supplied by you when you register on the Sites; and (ii) tracking information collected as you navigate the Sites. In particular, the FBA collects the following information from and about you:

• Registration information – Registration information is information you submit to register for a service, for example, to create an account, make a purchase, register for an event, enroll in a course, post comments, or receive a newsletter, and may include, but is not limited to, first name, last name, and email address.
• Sensitive data – We may collect limited sensitive data related to attendance at FBA events only as provided by you and with your consent, including passport information for visa and security processing; dietary restrictions and disability accommodations information.
• Public data and posts – This may consist of comments or content that you post on the Sites and the personal information about you that accompanies those posts or content, which may include a name, user name, or comments. Public information and posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.
• Research – If you have purchased our products or services or registered for events, education or other programs, we may request that you complete surveys, evaluations form and/or market research and collect your responses.
• Activity data – When you access and interact with the FBA services, we may collect certain information about those visits. For example, in order to permit your connection to the FBA services, our servers receive and record information about your computer, device and browser, including potentially your IP address, browser type, and other software or hardware information.
• Cookies, web beacons and similar technologies – Cookies are small text files placed on your device that uniquely identify your device and which a website can transfer to a consumer's hard drive to keep records of his or her visit to a website. Web beacons are transparent image files used to monitor your journey around a single website or collection of sites. Web beacons may be used in association with cookies to understand how visitors interact with the pages and content on the pages of a web site. These and related technologies may be used to collect and store information about your usage of the FBA Services, such as pages you have visited, other content you have viewed, search queries you have run and advertisements you have seen. For more information, see Section 8 below.

2. How Your Information is Used
We use the personal information we collect from and about you to:

• Provide our Sites, features, products, educational programs, and events to you;
• Measure and improve those Sites and features;
• Provide you with customer support and to respond to inquiries;
• Protect the rights of the FBA and others. There may be instances when we may disclose your personal information, including situations where we have a good faith belief that such processing is necessary in order to: (i) protect, enforce or defend the legal rights, privacy, safety or property of the FBA, our affiliates or their employees, agents and contractors (including enforcement of our agreements and terms of use); (ii) protect the safety, privacy and security of users of our Sites or members of the public; (iii) protect against fraud or for risk management purposes;
• Send marketing communications customized to your interests and needs in accordance with applicable law;
• Send surveys, evaluations or research questionnaires related to our products, services, events, educational and related programs;
• Send advocacy communications and voter information; and/or
• Comply with applicable laws or legal process and/or respond to requests from public and government authorities.

3. How We Process Your Personal Information
We process personal information per applicable law and with transparency and fairness. Our processing activities are conducted:

• With your consent;
• In order to fulfill our contractual obligations to you;
• For the legitimate purpose of operating our business, including to improve and develop our services, for fraud prevention purposes, and to improve use experience; or
• As otherwise in compliance with law.

4. How We Share Your Personal Information
The FBA may share your personal information for the purposes of Section 2 above to the following categories of recipients:

• Service providers, helping to administer the Sites, products, services, research educational programs and events;
• Subsidiaries and affiliates to better serve the FBA membership and its evolving needs;
• Sponsors and Exhibitors of our events;
• Third parties who provide products and services of interest to FBA members;
• Other association members for the purpose of performing trade association business;
• Companies which may be the result of any mergers, acquisitions, asset sales, joint ventures, etc.;
• Data Analytics Platforms, such as Google Analytics, to compile statistics and perform analysis intended to improve our services and user experience;
• Audience Data Providers, who, in certain countries, we may also work with, such as Facebook, Twitter, LinkedIn and others, to receive audience based data (such as pixel traffic and conversion data) from them based on non-identifiable information such as IP addresses; and/or
• Competent authorities, including law enforcement, in order to comply with applicable laws or court orders.

5. Applicable Law and Data Transfers
The FBA is headquartered in the State of Florida.  The Sites are intended for users in the U.S. By using or accessing our sites or otherwise using the Sites, you consent to the transfer of information to the U.S. to the extent applicable, and the collection, storage, and processing of information under U.S. laws. 
6. Your Rights with Regard to Your Personal Information
We give you choices regarding our use and disclosure of your personal information for marketing purposes. You may withdraw your consent to:
Receiving electronic communications from us – If you no longer want to receive marketing-related emails from the FBA, you may opt-out of receiving these by following the unsubscribe link in our communications or sending a request to the email or postal address in the Contact Us section below.
7. California Resident Privacy Rights
California law permits residents of California to opt-out of the FBA's disclosure of personal information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your personal information with third parties for marketing purposes at any time by contacting us at [email protected]. Please note that this opt-out does not prohibit disclosures made for non-marketing purposes. California law also permits residents of California to request and obtain from us once per year, free of charge, a list of the third parties (if any) to whom we have disclosed personal information for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to [email protected]. The email subject line must include the phrase "Your California Privacy Rights," and include your name, email address or mailing address.
We do not support "Do Not Track" browser settings and do not currently participate in any Do Not Track frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information. 
8. Cookies
We use, and allow certain third parties to use, cookies, web beacons and other similar technologies to enhance our Sites and to help collect data. We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device's hard drive until you delete them or they expire at thirteen months. Different cookies are used to perform different functions, which we explain below:

• Essential – Some cookies are essential in order to enable you to move around our websites and use their features, such as accessing secure areas of the website. Without these cookies, we cannot enable appropriate content based on the type of device you are using. These cookies allow us to remember choices you make on our websites, such as your preferred language and the country from which you are visiting, and provide enhanced, more personalized features.
• Performance and Analytics – We use our own cookies and/or third party cookies to see how you use our websites and services in order to enhance their performance and develop them according to your preferences. We may use Google Analytics, for example, to track website usage and activity. You can opt-out of the Google Analytics Advertising Features we use by indicating your preference using the Google Analytics User Deletion Tool here. Note that Google's opt-out mechanism is specific to Google activities and does not affect the activities of other ad networks or analytics providers that we may use.
• Targeted Advertising – We may receive audience based data (such as pixel traffic and conversion data) from social media platform providers, including Facebook, LinkedIn and Twitter and others based on non-identifiable information such as IP addresses. We may use this information to serve ads to you. To block or limit this activity, please visit the sites below:
  • Twitter: https://support.twitter.com/articles/20170405
  • Facebook: You should see a link to the opt-out when you select "Why am I seeing this?" when using Facebook. You can also select "Hide all from this advertiser" within Facebook to stop seeing our ads. More information can be found on Facebook's site here: http://www.facebook.com/business/help/1415256572060999
  • LinkedIn: https://www.linkedin.com/help/linkedin/answer/62931/manage-advertising-preferences
• Third Party Advertising and Social Media – We may allow other third parties to place cookies on our websites to allow them to show you advertisements both on and off our websites that are more relevant and useful to you. These advertisers and other third parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content are part of the group that the ad or content is directed towards.

How to Manage Cookies
There are several ways to manage cookies. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. Please note, however, that many of the cookies we use are "strictly necessary" cookies. By blocking or deleting them, you will not be able to access certain features of our Sites. For more information about cookies and how to block them, please visit www.allaboutcookies.org.
In the US, the Network Advertising Initiative also offers a means to opt out of a number of advertising cookies. Please visit www.networkadvertising.org to learn more. Note that opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
9. Security Notice; Retention
FBA takes the security and privacy of your personal information seriously. Please be aware, however, that no data transmission over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us. Understand that any information that you transfer to us is done at your own risk. If we learn of a data security systems breach we may attempt to notify you electronically regarding security, privacy, and administrative issues relating to your use of the Sites. We may post a notice on the Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive written notice of a data privacy or security breach.
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
10. Assignment
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal information we have collected from you.
11. Links to Third Party Websites
The Sites contain links to other websites. The FBA is not responsible for the privacy practices of unaffiliated companies, and once you leave the FBA Sites, you should read the applicable Privacy Policy of the other service.
12. Updates to this Privacy Policy
We may update this Privacy Policy from time to time, so please visit this page periodically and review for changes. We will notify you of material changes to this Privacy Policy by posting a notice on our home page for a reasonable period of time and changing the "Effective Date" above. Your continued use of our Sites following the posting of changes will constitute your acceptance of the changed terms.
13. Contact Us
Your visit to the Sites is subject to both this Privacy Policy and our Terms of Use. If you have any questions, comments or concerns regarding this Privacy Policy, please contact us at:
The Florida Bankers Association
Attn: Website Manager
1001 Thomasville Road, Suite 201
Tallahassee, FL  32303
[email protected]