This privacy policy (“Privacy Policy”) applies to how the Enzyme Technical Association (“ETA”) communicates with you and informs you of updates on ETA, including information on our events and services, industry news and important regulatory and legislative happenings. This means ETA may get in touch with you from time to time with useful information. We enjoy valuable communication with all our contacts and will not send spam email.

By continuing to receive communications from ETA, you agree to the terms of this Privacy Policy. Please note that the Privacy Policy does not apply to other organizations, other websites of other companies, or third party sites that link to us. If you reside in Europe please refer to the Addendum, “European Data Privacy Laws” of this Privacy Policy as well, which includes additional rights in relation to your personal information.

ETA Information Collection
Generally, you are not required to provide information about yourself when you visit the ETA website or its features (the “Website”), but we will collect your personal information in the course of our regular business, for example, including but not limited to when you register for a committee meeting or event, or initially upon completing an application for membership, or if you request to be on an ETA-generated email list.

In addition, you can browse the Website and view our content anonymously.  However, we may ask you for (or collect from you) some or all of the following types of information when you access various website content or features, submit information to us, or directly contact us with questions or feedback:

• contact information, such as name, email address, phone number and postal address;
• geolocation information based on IP addresses;
• correspondence and other information that you send to us; and
• additional information as otherwise described to you at the point of collection or pursuant to your consent, (collectively, “personal information”).

We may collect certain information automatically through Google analytics or ask your browser to store cookies, a small piece of data, on your computer or mobile device when you visit the Website. A cookie can be used to enable a site to remember information that you previously input. It also helps deliver content-specific information to you and tracks how sections of the Website are used.  You can change your browser settings to erase cookies from your computer’s hard drive, block all cookies, or receive a warning before a cookie is stored.  Please check your Internet browser’s instructions to learn more about these functions. If you do not allow cookies being installed on your browser, ETA may not be able to provide you full access to all the functionality of our Website.

Use of Information
We may use information that we collect from you for a variety of purposes, including, but not limited to:

• provide you with the services, newsletters, and information you request;
• respond to correspondence that we receive from you;
• contact you via email and otherwise about information that we think might be of interest to you;
• maintain or administer the Website, perform operational analyses, or for other internal purposes to improve the quality of our operations, services, and other features we offer or may offer from time to time;
• provide you with services associated with ETA; and
• as otherwise described, or pursuant to your consent.

Sharing of Information
We seek to maintain your trust, and we want you to understand when and with whom we may share the information we collect:

• Service Providers and Vendors: We may share your information with service providers that perform certain functions on our behalf (such as to fulfill requests, provide services, manage databases, perform analyses, provide customer service, or send communications for us).
• Administrative or Legal Process: We may disclose your information to third parties in order to protect the legal rights, safety, and security of our organization, and the users of our Website; respond to and resolve claims or complaints; prevent fraud or for risk management purposes; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required, or for compliance with any other legal obligations.
• To carry on the regular business of our Association; which includes, but is not limited to, our regular distribution of draft documents for comment to member or member/non-member coalition email lists for group review and comment, or vote. Your email address (and possibly other contact information) will be shared with all recipients on such email distribution lists.

Personal Information
In order to participate in ETA activities, you are required to provide (voluntary and at your option) certain personal information (e.g., email and work addresses).
It is our policy to not disclose externally to third parties personal information collected, except in the following instances:

• we may disclose personal information to third parties (and our members) (1) when required by law or when the information is pertinent to judicial or government investigations or proceedings; (2) to protect and defend our rights and property; (3) when necessary to protect our interests, our Website, the safety of its users, or the public; or (4) to carry on the regular business of our Association (e.g., we regularly distribute by email draft documents for comment to member or member/non-member coalition mailing lists for group review and comment. Your email will be shared with all recipients on such email distribution lists. Following such distribution, ETA has no control over the recipients’ further use of your personal information. If you do not wish to have your email address circulated as part of these group distribution lists, you will not be able to receive such ETA correspondence.

Other than as set forth above, we currently do not intend to share your personal information with third parties for other purposes. However, in the future, we may disclose personal information you have provided to third parties for additional purposes. In the event we do, we will provide notice of such use to our service users as appropriate, i.e., to those that have allowed us to communicate with them.

Information Correction or Changes
You have the ability to request a correction or change of certain information in our records, such as your email address and other contact information. Generally, you may request a change of this information at any time and as often as necessary. If you need assistance or have questions about correcting information, you can contact us via email at: Ann.Begley@morganlewis.com

Security
We have industry standard security procedures and best practices to help protect against loss, misuse, and unauthorized access to the information you provide to us. Please note, any data transmission or storage cannot be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Website or via email and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

Notification of Changes
Periodically we may make changes to this Privacy Policy. You are responsible for periodically checking our Website for changes to this Privacy Policy. Your continued membership, use of our databases and/or use of our Website after these changes are posted constitutes your agreement to the changes with regard to any information collected.

Contact Information
We welcome your feedback regarding this Privacy Policy. If you have any comments, questions or concerns about this privacy policy you may contact us at: Ann.Begley@morganlewis.com

The Addendum
European Data Privacy Laws
If you are a European resident individual or company, you have certain rights in relation to your personal information under the applicable European data privacy laws. This Addendum only applies to such users. Under applicable European data privacy laws, ETA is the data controller.
IF YOU DO NOT AGREE WITH ANY TERMS OR PRACTICES DESCRIBED IN THIS PRIVACY POLICY, YOU MAY ELECT TO BE REMOVED FROM ETA’S DATABASES AND EMAIL DISTRIBUTION LISTS AND NO LONGER RECEIVE ANY COMMUNICATIONS FROM ETA.

Rights to Control Your Personal Information
Applicable European data privacy laws give certain users the right to access their personal information. Your right of access can be exercised in accordance with the European data privacy laws. If you would like to request a copy of your personal information being held by us, or request that it is deleted or to update and/or correct your personal information or request that we provide a copy to another data controller of your personal information that you have provided to us, please contact us. We will need enough information to ascertain your identity as well as the nature of your request. We will aim to respond to your request within one calendar month of receipt of the request. Where we were unable to do so within the calendar month, we will notify you of the soonest practicable time within which we can respond to your request (and within three months from the date of your request). There are certain exemptions and restrictions of these rights under the European data privacy laws that enable personal information to be retained, processed or withheld from access and we will inform you of these if applicable. If you would like to exercise any of these rights, please use the contact information in the main Privacy Policy.

We use your Personal Information for the following key purposes:

• to contact you: subject to applicable law, we or our third-party service and business providers may send you communications; especially if you have signed up for one of our email distribution lists. Such communications are designed to make your experience with ETA more efficient and may include, but are not limited to: communications about our organization and other notifications including important news. Where required under applicable data privacy laws, we will not send you marketing communications without your prior consent;
• for legal purposes: we may use and share personal information for legal purposes, including financial, regulatory, tax and other legal obligations and to respond to governmental or regulatory requests or subpoenas or for litigation purposes;
• for our legitimate interests and those of a third party: we may use your personal information to manage our legal, regulatory, financial and business requirements, including obtaining legal advice, in the course of disputes and litigation, internal and/or regulatory investigations and other legitimate interests;
• for our business purposes: we may use your personal information to help us manage the objectives of our organization;
• for other purposes: subject to applicable law, we may use your personal information for additional purposes in connection with the Website or our organization, where you have been notified.

Emails or Text Messages
If you have provided us with your email address or mobile phone number to receive correspondence as part of a distribution list as set forth in the section, Sharing of Information, or otherwise receive notifications or updates, and you wish to change your address or no longer wish to receive these communications, please contact us at: Ann.Begley@morganlewis.com.

Please note, any information we have collected may remain in back-up storage, archival, and/or log files, for some period of time after a deletion request. This may be the case even though no information about your account remains actively used as described in this Privacy Policy.

International Transfers
Your personal information will be processed in the US (which may have less stringent data privacy laws compared to those in your country of residence) and we also transfer your personal information to the recipients described in the Sharing of Information part of this Privacy Policy including those recipients located in countries which may also have a less stringent standard of data privacy laws compared to those in your country of residence. Where this occurs, you acknowledge consent to such transfer in accordance with this Privacy Policy.

Sharing your personal information
We share your personal information with third parties to help us use your personal information, as described in the Privacy Policy and in addition, we may need to share your personal information with our professional tax, legal, audit or financial advisors. We may also share your personal information when we receive requests for information in the context of legal disputes, investigations regulatory enquiries or similar requests.

Tracking Tools (“Cookies”)
We may collect certain information automatically through Google Analytics or ask your browser to store cookies, a small piece of data, on your computer or mobile device when you visit the Website. A cookie can be used to enable a site to remember information that you previously input. It also helps deliver content-specific information to you and tracks how sections of the Website are used. You can change your browser settings to erase cookies from your computer’s hard drive, block all cookies, or receive a warning before a cookie is stored. Please check your Internet browser’s instructions to learn more about these functions. If you do not allow cookies being installed on your browser, ETA may not be able to provide you full access to all the functionality of our Website.

Retention of personal information
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and applicable legal requirements.

Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, except as set forth in this Privacy Policy, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

Complaint Process
If you have any concerns regarding how we are handling your personal information, please contact us. We will strive to deal with your concerns promptly. If you wish to complain about the handling of your personal information outside of ETA, you have the right to raise a complaint with a supervisory authority in your country of residence if applicable under European data privacy laws.