This policy describes how The American Association of Procurement, Supply Chain and tourism Management Professionals otherwise known as the American Association of Procurement and Supply Chain Management. (“AAPSCM®”) collects, uses, and shares personal information. Please note: You can jump to particular topics by going to the headings below: Types Of Information We Collect. Use and Processing Of Information Sharing Of Information. Your Choices. How We Protect Personal Information Miscellaneous Contact Information Types Of Information We Collect. The following provides examples of the type of information that we collect from you and how we use that information.

Context	Types of Data	Primary Purpose for Collection and Use of Data
Account Registration or Membership Application	We collect your name, contact information, and professional information such as your company or industry when you create an account. We also collect information relating to the actions that you perform while logged into your account.	We have a legitimate interest in providing account related functionalities to our users. Accounts can be used to save your preferences and transaction history.
Certification	We collect attendance records from events, meetings, or examinations, as well as the information you enter on exams (which may include video of you and your surroundings if you select the online testing option), customer service interactions, and any certification verification requests that you have made.	We have a legitimate interest in ensuring that our certification standards are being met, including when and how our members are verifying those certifications.
Cookies and first party tracking	We use cookies. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed.	We have a legitimate interest in making our website operate efficiently.
Cookies and Third-Party Tracking	We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites.	We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics.
Demographic Information	We collect personal information, such as your age, gender, or location.	We have a legitimate interest in understanding our users and providing tailored services.
Email Interconnectivity	If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.	We have a legitimate interest in understanding how you interact with our communications to you.
Feedback/Support	If you provide us feedback or contact us for support, we will collect your name and e-mail address, as well as any other content that you send to us, to reply.	We have a legitimate interest in receiving, and acting upon, your feedback or issues.
Mailing List	When you sign up for one of our mailings lists we collect your email address or postal address.	We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.
Mobile Devices	We collect information from your mobile device such as unique identifying information broadcast from your device and location when visiting our website or using our application.	We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Partner Promotion	We collect information that you provide as part of a co-branded promotion with another company. We may also have service providers collect information on our or our partners’ behalf.	We have a legitimate interest in fulfilling our promotions.
Surveys	When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.	We have a legitimate interest in understanding your opinions and collecting information relevant to our organization.
Website interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud or other security incidents.
Web logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, our affiliates, or publicly available sources. For example, we may receive information on graduates from a university or an employer. Use And Processing of Information. In addition to the purposes and uses described above, we use information in the following ways:

• To identify you when you visit our website.
• To track your progress through our certification programs.
• To verify your certifications when requested by you or a third party.
• To provide training and services or to process returns.
• To improve our services and product offerings.
• To conduct analytics.
• To respond to inquiries related to support, sales, or other requests.
• To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
• For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you register for membership, we may collect your information to perform our contract with you. But we also collect your information as we have a legitimate interest in maintaining your information after your membership concludes so that we can quickly and easily respond to any questions about your history with the organization. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in maintaining our programs. Sharing Of Information. In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

1. Affiliates and Acquisitions.We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
2. Other Disclosures with Your Consent.We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
3. Other Disclosures without Your Consent.We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
4. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
5. Partner Promotion.We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
6. Service Providers.We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.

Your Choices. You can make the following choices regarding your personal information:

1. Access To Your Personal Information.You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
2. Changes To Your Personal Information.We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain information, contact us at the address described below.
3. Deletion Of Your Personal Information.Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
4. Objection to Certain Processing.You may object to our use or disclosure of your personal information by contacting us at the address described below.
5. Online Tracking.We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
6. Promotional Emails.You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
7. Revocation Of Consent.If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

How We Protect Personal Information No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account. Miscellaneous The following additional information relates to our privacy practices:

• Transmission Of Information to Other Countries.As a multi-national non-profit, we transmit information between and among our affiliates. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
• Third Party Applications/Websites.We have no control over the privacy practices of websites or applications that we do not own.
• Changes To This Privacy Policy.We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy.
• Information for California Residents.California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we share below.

California Information Sharing Disclosure California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that organizations should disclose whether the following categories of information are collected, transferred for consideration, or transferred for an organization’s “business purpose” as that term is defined under California law. Note that while a category may be marked that does not necessarily mean that we have information in that category about you. For example, while we collect professional information from those who submit an application for membership with us, we do not collect or transfer professional information of individuals that submit questions on our website’s “contact us” page. Nothing set forth below shall be construed to constitute an admission that CompTIA or any of its affiliates are “businesses” under CCPA.

Category of Personal Information	Is information collected by us?	Is information transferred for valuable consideration?	Is information transferred for business purposes?
Audio, electronic, visual, thermal, olfactory, or similar information	✓		✓
Bank account number	✓		✓
Biometric information
Characteristics of protected classifications (e.g., age, sex, race, ethnicity, physical or mental handicap, etc.)	✓		✓
Commercial information (e.g., products or services purchased, or other purchasing or consuming histories or tendencies)	✓		✓
Credit card number	✓		✓
Debit card number	✓		✓
Driver’s License Number / State ID	✓		✓
Education	✓		✓
Electronic network activity (e.g., browsing history)	✓		✓
Email address	✓		✓
Employment	✓		✓
Employment history	✓		✓
Geolocation data
Health insurance information
Identifiers (e.g., name or alias)	✓		✓
Insurance Policy Number
Medical information
Other financial information	✓		✓
Passport Number	✓		✓
Physical Characteristics
Postal address	✓		✓
Signature	✓		✓
Social Security Number
Telephone Number	✓		✓
Transaction information	✓		✓

• Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the “Contact Information” section below.

Contact Information. If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information. privacyteam@AAPSCM®.org (833) 524-2846 If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority. EU data subject may also inquire about our privacy practices by contacting us as set forth below: privacyintervention@AAPSCM.org Effective Date: January 01, 2020