Privacy Policy

The Sugar Association (“SAI” “we” or “us”) cares about your privacy and the security of your information. This Privacy Statement describes how we collect and otherwise process your Personal Data (as defined below) in connection with:

• Your use of and contact through the SAI website (the “Site”);
• Your company’s membership in SAI;
• Your attendance at SAI events, seminars, and other meetings; and
• Other scenarios where we present or link to this Privacy Statement.

The Sugar Association is the data controller of the Personal Data we collect under this Privacy Statement.

Personal Data We Process

“Personal Data” refers to any information that relates to you directly or indirectly. We process the following categories of Personal Data:

• Contact information, such as your name, address, email address, phone number, and business contact information;
• Technical information, such as data collected about your interaction with our websites;
• Financial information, such as payment card and related information (sometimes through third parties who collect and process your financial information on our behalf);
• Identification or background information, provided by you or collected by third parties as part of our assessment of your membership applications, research, and other engagements
• Pictures; and
• Any other information that you provide that can be used to identify you.

We collect your Personal Data from:

• Direct interactions, such as when you become a member, sign up for a newsletter, register for an event, participate in surveys or questionnaires, or in any way engage with our personnel;
• Cookies and automated technologies, such as when you interact with our website or click on links on our emails;
• Third parties, when the circumstances arise, such as when we sponsor a conference and receive the conference attendee list from the conference organizer; and
• Through social media, such as if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform.

In addition to Personal Data, we may collect information that does not relate to an identified or identifiable person. For example, we may collect the browser types, device types, and operating system information of our users. If any of this information can be used to identify you because, for example, we link it to your Personal Data, we will treat such information as Personal Data.

How We Use Your Personal Data

We, or our service providers, use your Personal Data for various purposes depending on the types of information we have collected from and about you, in order to:

• Register you for and provide you access to your online account;
• Obtain your subscription preferences and send eNewsletters and similar marketing communications;
• Respond to inquiries, fulfill requests, and otherwise deliver customer service;
• Conduct surveys and questionnaires;
• Register you for events and deliver event-related materials;
• Perform website analytics;
• Obtain current contact information and update contact records in our CRM;
• To comply with our legal obligations; or
• For other purposes as disclosed at the time of collection.

We reserve the right to use information that is not Personal Data (such as anonymous information) for any legal purpose.

How We Share Your Personal Data

We will share your Personal Data within SAI, at your direction, as disclosed to you at the time of collection, or in the following circumstances:

• Service Providers: We may provide your Personal Data to our service providers that help us run and manage our organization and process Personal Data solely on our behalf. The categories of service providers include: technology service providers, analytics service providers and marketing service providers.
• Corporate Transaction: In the event SAI is involved in a merger, reorganization, acquisition or sale of all or a portion of its assets, or other corporate transaction, we may disclose your Personal Data as part of that transaction.
• As Required By Law: We may disclose your Personal Data if we determine that the disclosure is necessary: (i) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to protect the legitimate rights, privacy, property, interests or safety of SAI, our business partners, personnel, or the general public; (iv) to pursue available remedies or limit damages; (v) to enforce our policies and procedures; or (vi) to respond to an emergency.

Note to International Users

SAI is committed to complying with this Privacy Statement and the data protection laws, including those outside of the United States, that apply to our collection and use of your Personal Data. SAI is located in the United States, and we recognize that the laws in the United States may be different and, in some cases, less protective as the laws other countries, including the European Economic Area (“EEA”). By providing us with your Personal Data and using our Site, you acknowledge that your Personal Data will be transferred to and processed in the United States.

If you are located in the EEA, we have identified the following legal basis for the processing of Personal Data that we collect under this Privacy Policy:

• Where use of your Personal Data is necessary to perform our obligations under a contract with you (for example, to comply with any terms you have agreed to as part of your membership in SAI);
• Where use of your Personal Data is necessary for our legitimate interests or the legitimate interests of others (for example, to provide membership services; provide security for our website and applications; make and receive payments; comply with legal requirements and defend our legal rights; and to prevent fraud);
• Where we are required to process Personal Data in accordance with a legal obligation; or
• Where we have your consent, in accordance with applicable law.

If you would like to know more about how we process your Personal Data, you can contact us using the information in the section “Contact Us” at the end of this Privacy Statement.

Use of our Site / Data Collection Technologies

Cookies and Other Data Collection Technology: We use Cookies, Web Beacons (also known as pixel tags and clear GIFs) and other similar technology (together, “Data Collection Technology” on our Site. A “Cookie” is a small text file that is sent to or accessed from your web browser or your computer’s hard drive. A Cookie typically contains the name of the domain (internet location) from which the Cookie originated, the “lifetime” of the Cookie (when it expires), and a randomly generated unique number or other similar identifier. A Cookie may also contain information about your computer, such as user settings, browsing history and activities conducted while using our online services. A “Web Beacon” (also called a “pixel tag” or “clear GIF”) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org. You can opt out of receiving targeted advertising at www.aboutads.info.

Data Collection Technology helps us improve your experience on our online services. For example, we use Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing Cookies on your device. The information that the Cookies collect, such as the number of visitors to the website, the pages visited and the length of time spent on the website, is aggregated. We also may use Data Collection Technology to collect information from the computer or device that you use to access our online services, such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject Cookies or alert you when a Cookie is placed on your device. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through our online services.

Our Policy on Do Not Track Signals: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes; however, we do not currently recognize or respond to browser-initiated DNT signals.

Third Party Website and Services

When interacting with us, you may come across links or references to third party websites and services that we do not operate or control. If you provide your Personal Data to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies. This Privacy Statement does not apply to any Personal Data that you provide to a third-party website or service. We recommend that you read the privacy policy that applies to that third party website or service. A link or reference to a third-party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.

Security

We have implemented appropriate technical and organizational measures designed to protect your Personal Data from unauthorized access, use, disclosure, alteration, or destruction, in accordance with applicable laws and regulations. For example, we limit our collection and use of your Personal Data to

the extent reasonably necessary to provide you with our services. However, no Internet or email transmission is ever 100% secure, and we encourage you to take reasonable precautions to safeguard your Personal Data by, for example, maintaining the confidentiality of your account username and password. If you would like to know more about how we protect your Personal Data, you can contact us using the information in the section “Contact Us” at the end of this Privacy Statement.

Retention of Personal Data

We will keep your Personal Data for as long as necessary to fulfill the purposes for which we collected it, including any legal, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, whether we can achieve those purposes through other means, and all applicable legal requirements.

Children’s Privacy

Our services are not directed to or intended for use by minors. Consistent with applicable laws, if we learn that we have received Personal Data directly from a child without his or her parent or legal guardian’s verified consent, we will use that Personal Data only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such Personal Data.

Marketing

If you do not wish to receive marketing-related emails from us, please click the unsubscribe link at the bottom of any marketing email, or email us using the information in the section “Contact Us.” Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.

Your Rights

You may request to access or correct the Personal Data we maintain about you, and we will respond to your inquiry within a reasonable timeframe. If you wish to exercise these rights (including those described below for individuals in the EEA, as applicable), please contact us using the information in the “Contact Us” section at the end of this Privacy Statement. We may charge you a reasonable fee if you request additional copies of your Personal Data or make other requests that are manifestly unfounded or excessive. Further, we may not be able to honor your requests in certain circumstances. If we are unable to honor your request, or before we charge a fee, we will let you know why.

Please note that if you decide to exercise some of your rights, we may be unable to provide you certain services, or you may not be able to use or take full advantage of the services we offer.

Additional Rights for Individuals in the EEA: If you are located in the EEA and we maintain your Personal Data, you have the following additional rights (under the EU General Data Protection Regulation) with regard to your Personal Data:

• Right to access and receive: You may request a copy of or access to the Personal Data we hold about you. You may also request that we transfer your Personal Data to a third party in a machine-readable format.
• Right to correct: You may ask us to update or correct inaccurate or incomplete Personal Data we hold about you.
• Right to limit or restrict: You may have the right to request that we stop using all or some of your Personal Data or to limit our use of it.
• Right to erase: You may have the right to request that we delete all or some of your Personal Data.
• Right to withdraw consent: You have the right to withdraw any consent you have previously given to SAI at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your Personal Data prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your Personal Data if it has been fully anonymized and cannot be used to personally identify you.
• Right to complain: You have the right to lodge a complaint with your Supervisory Authority if you are unhappy with how we process your Personal Data. You can find contact information for your Supervisory Authority on the European Commission Data Protection Authorities webpage or through other publicly available sources.

Special Notice to California Residents

California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Data to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information in the “Contact Us” section below. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below. Note that we do not currently share Personal Data with third parties for those third parties’ direct marketing purposes.

Changes to this Privacy Statement

We state the Effective Date of this Privacy Statement at the top of this page. If we materially change the way we use or disclose your Personal Data we will notify you in advance by email and/or by placing a prominent notice on this website. The amended Privacy Statement supersedes all previous versions. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

We welcome your questions and comments about this Privacy Statement or how we process your Personal Data. Please contact us using the information below and we will respond to you as soon as reasonably possible.

The Sugar Association
1310 L St. NW Ste 400
Washington DC 20005
Phone: (202) 785-1122
Email: sugar@sugar.org