Created: July 2022

Detroit Regional Chamber (“Chamber”) is committed to protecting the privacy of individuals and has created this Privacy Policy in compliance with the law and in order to demonstrate our firm commitment to privacy. The following discloses our information gathering and dissemination practices for the Chamber’s related websites detroitchamber.com and michauto.org (the “Sites”). The terms “we” and “our” refer to Chamber and all associated companies and subsidiaries.

This Site is hosted in the United States and intended for U.S. Site visitors. If you are visiting this Site from outside of the United States, please note that by providing your information it is being transferred to, stored, or processed in the United States where our data center and servers are located and operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our web site, you understand that your information will be transferred to our facilities in the United States and to third parties with whom we may share your information. If you are visiting this Site outside the United States and do not wish to allow the transfer of your personal information to the United States, you should not use this Site. See our Cookies Policy and instructions below.
We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information where we have legitimate interest and in accordance with the law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.

COLLECTION AND USE OF INFORMATION:
We collect personal information from correspondence, faxes, texts, live chats, e-mails, telephone inquiries, web forms, and other means of communication. We collect such information when we provide you with access to community and regional resources and services, and other lawful purposes. We (and our affiliates and authorized service providers) may collect, store and use:

1. Information about your visits to and use of this Site.
2. Information about any transactions conducted between you and us on or in relation to this Site, including information relating to any resources, services and/or subscriptions.
3. Any information you provide to us if you correspond or communicate with us.
4. If you create or attempt to create a business relationship with us, we may ask you for your name, organization, age, geo-location and other demographic information, e-mail address, street address or other personal information, such as biographical information.

We also may collect information about your computer or mobile device and your visits to this Site, such as your IP address, geographical location, browser type, referral source, length of visit and number of page views. We may use this information in the administration of this Site, to improve the Site’s usability, to provide better service, to send you newsletters, legal updates, marketing communications, and other information that may be of interest to you. We also use outside services such Google Analytics to gather data about our Site visitors. We may sometimes permit our authorized service providers to have access to aggregate statistics about our clients, Site traffic patterns, usage, and related information.

We may share information with trusted third parties who assist us in operating our website and in conducting our business and business relationship with you. Third parties include, as examples, organizations that perform outsourcing and other services for us (such as marketing, payment processors, shipping companies, other Detroit community organizations, and systems development and maintenance organizations).

We may share your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Chamber’s business or assets to such business entity (including due to a sale in connection with a bankruptcy or dissolution). We will require any such purchaser, assignee, or other successor business entity to honor the terms of this privacy statement.

We do not allow third parties to collect personal information about your online or mobile activities over time and across different web sites or mobile devices when you use the Site. We also will not sell your personal information.

We rely on the following legal grounds to process your personal information, namely:

• Performance of a contract – We may need to collect and use your personal information to enter into a contract or to perform a contract that you or your company has with us.
• Consent – Where required by applicable law, we will rely on your consent for collecting your personal information.
• Legitimate interests – We may use your personal information for our legitimate interests to improve our services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable law, we may use technical information as described in this Privacy Policy and use personal information for our marketing purposes.

Our Site uses first and third-party cookies for technical, analytical, and advertising purposes. “First party cookies” refer to cookies that are set by our Site, and we are the only ones with access to this information. On the other hand, “third party cookies” or requests allow other third parties to have access to the information collected. Not all cookies are necessary to navigate this Site. Cookies used for analytical and advertising purposes, such as site analytics and advertising cookies (non-essential cookies) are not necessary to navigate our Site. You have the choice not to accept or delete them anytime and continue browsing normally. See below for instructions.

Cookies are files that are downloaded on your computer or mobile device when you visit certain websites. Cookies allow a website, for instance, to identify a user session, recall your preferences (e.g., language), or gather information about your browsing habits. We use essential cookies for our legitimate interest in facilitating your access to and use of the Site, and we ask your consent for using advertising and analytics cookies (non-essential cookies) so we can measure how you interact with the Site content. However, you can withdraw your consent at any time by not allowing cookies.

We may send a cookie which may be stored by your browser on your computer’s hard drive. We use this information for the following purposes:

• Assisting you in navigation on the Site
• Improve the functionality of the Site
• Store login details for our secure Site(s)
• System administration
• Reporting information for research purposes
• Assisting with our promotional and marketing efforts.

We also may use “clear gif” pixels in HTML-based emails sent to our users to track which emails are opened by recipients. We may use the information we obtain from the cookie in the administration of this Site, to improve the Site’s usability and for marketing purposes. We may also use that information to recognize your computer or mobile device when you visit our Site, and to personalize our Site for you.

Cookies and information captured through this Site are stored for a certain retention period; however, you can eliminate these cookies any time before the cookie expiration date.

You can adjust the settings in your browser to restrict or block cookies that are set by the Services (or any other site on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer.

You can control and delete these cookies through your browser settings through the following link: https://allaboutcookies.org/how-to-clear-cookies.

Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.

Please be aware that restricting cookies may impact the functionality of the Services. Most browsers allow you to refuse to accept cookies. (For example, in Edge you can refuse all cookies by clicking “Settings”, “Cookies and Site Permissions”, “Manage and delete cookies and site data”, and turn off “Allow sites to save and read cookies data”) This will, however, have a negative impact upon the usability of many websites, including this one.

The Site contains links to other sites. Chamber is not responsible for the privacy practices or the content of such websites, including any sites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). We do not share information we gather with other websites or any other entities or individuals unless such sharing is approved in advance by you. Other linked sites, however, may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the sites you may visit by linking from the Site. Please note that this Privacy Policy applies only to our Site, and not to other companies’ or organizations’ websites to which we link.

For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you’ve provided to them, or they’ve collected from your use of their services. This information may be stored in Google’s servers in the United States of America according to their privacy practices.

We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored, or used by such third-party sites or to whom it is disclosed. You should review the privacy policies and settings on any social networking site that you subscribe to so that you understand the information they may be sharing. If you do not want your networking sites to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information. We are not responsible for how these third-party sites may use information collected from or about you.

Chamber employs security measures utilizing industry-standard technology to protect the loss, misuse, or alteration of personal information that you disclose through the Site. Personal information is stored in a secured database and always sent via an encrypted Internet channel. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly at privacy@detroitchamber.com. To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect member privacy in all aspects of their work. Any employee who violates our privacy policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.

Chamber may disclose personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with Chamber, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Site users, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. Chamber may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services.

Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Chamber does not process or respond to “Do Not Track” signals.

The Child Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personally identifiable information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personally identifiable information through the site. If you are under the age of 18 and have already provided personally identifiable information through the site, please have your parent or guardian contact us immediately at privacy@detroitchamber.com so that we can remove such information from our files.

We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.

We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond that reasonably required for such purposes, or to comply with its obligations under applicable law.

We may keep a record of your personal information, including correspondence or comments, in the applicable file specific to you. We will utilize, disclose, or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal compliance and data retention policies.

Subject to the exceptions provided by the applicable law, we will make available to you any specific personal information about you that we have collected, utilized, or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. Simply send your request for access to the Privacy Director listed by sending an e-mail to privacy@detroitchamber.com. Please be as specific as possible in your request so that we can meet the applicable timelines.

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information.

If you are a resident of the European Economic Area (EEA) the General Data Protection Rule (GDPR) allows Data Subject rights of access, rectification, erasure, restriction, objection, or portability in line with the type of services being provided and the right to lodge a complaint to your Supervisory Authority.

We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate privacy commission with respect to this time limit.

We expect to provide access without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction, or transmission of such information. We will notify you, following your request for transcription, reproduction, or transmission, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use, or disclosure of your personal information in our possession. Any such information shall be used only for this purpose.

Personal information is generally located at our corporate or divisional offices in the United States. A list of corporations, divisions, subsidiaries, and affiliates to which this Privacy Policy applies is available upon request. Please direct all complaints or other inquiries regarding personal information, the Privacy Policy and Cookies Policy to our Privacy Director as follows.

Privacy Director
One Woodward Avenue, Suite 1800, Detroit, MI  48226
privacy@detroitchamber.com

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide advance notice on this Site. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Minor changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the Site constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the Site immediately. If you have any questions about this Privacy Policy, the practices of the Site, or your dealings with the Site, you can email privacy@detroitchamber.com.