Throughout the website there are several forms that request information and/or allow you to purchase products and services. These forms typically ask for contact information (such as name and address), membership number, and financial information (such as credit card number and expiration date) required to process your request. The provision of such information is entirely voluntary and any information provided through these forms is used to send the promotional information, products or services requested. You may opt out of receiving future mailings from the International Society by following the procedures detailed in the Choice/Opt Out section below.

Choice/Opt Out

Last Updated: February 1, 2024

1. Introduction

The International Foundation of Employee Benefit Plans (together with its subsidiaries, divisions, and brands, collectively, the "International Foundation," "us," "we," or "our," as the context may require) operates and provides the websites located at www.ifebp.org, fr.ifebp.ca, www.iscebs.org, www.welcoa.org, and www.nwi.org  (the "Sites"). This Privacy Policy (this "Policy") describes our privacy practices for the Sites, including the types of information we may collect from you when you visit or use the Sites and our practices for collecting, using, protecting, and disclosing that information. We respect the privacy of the visitors and users of the Sites ("you" or "your," as the context may require) and we are committed to protecting your privacy and the security of your personal information through compliance with this Policy.

Please read this Policy carefully to understand our practices regarding your personal information. By accessing or using the Sites, you agree to this Policy and any other applicable policies. If you do not agree with our policies and practices, please do not visit, access, use, or otherwise interact with the Sites.

2. The Interactions this Policy Covers

This Policy describes and applies exclusively to personal information (as defined below) that we collect on or in connection with the Sites and in texts, emails, and other electronic communications sent through or in connection with the Sites. Except as otherwise provided in this Policy or as required by applicable law, this Policy does not apply to information that is collected by any website or app other than the Sites. If you visit a website or app that we mention or link to, be sure to review its privacy policy before providing it with any information, as that privacy policy will apply to your interactions with that website or app.

Except as otherwise provided in this Policy, "personal information" is information that identifies, relates to, describes, is capable of being associated with, or otherwise could reasonably be linked, directly or indirectly, with you. "Personal information" does not include information which is generally not considered "personal information" under applicable law or is otherwise exempted under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations, or information not otherwise considered "personal information" under applicable law.

3. Information We Collect

We collect several types of information from and about you as a result of your use of or registration with the Sites and as a result of your communication with us. This information may include:

• Various categories of personal information, such as:
  • Identifiers, including your name, username, physical address, email address, phone number, and other similar identifiers.
  • Commercial information, including your payment information when you purchase a membership.
  • Location information.
  • Professional or employment information, including your company and title, and your education and work history when you apply to work with us.
  • Information about your internet connection and the equipment you use to access the Sites; IP address, approximate location, and other unique device identifiers; your activity on the Sites; and other usage details collected through your use of the Sites.
  • Inferences drawn from any of the above.
  • Any other personal information that you voluntarily share on the Sites, or which you otherwise provide directly to us.

We may also collect information that is about you but individually does not identify you, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify you.

4. How We Collect Personal Information

We may collect personal information:

• Directly from you when you provide it to us;
• Automatically when you use or access the Sites; or
• From third parties.

Your consent to our collection, use, and disclosure your personal information as provided in this Policy may be provided in writing, electronically, implied by using the Sites, by signing up for a membership, allowing cookies, and otherwise electronically interacting with us. Subject to certain exceptions, you can withdraw your consent to our collection, use, and disclosure of your personal information at any time by contacting us as provided in Section 12 (How to Contact Us).

Your decision to withhold or withdraw your consent may restrict your ability to interact with the Sites or our ability to fully provide you full access to the Sites and other products or services.

A. Information We Collect Directly

The personal information we collect directly from you when you use or access the Sites includes:

• Information that you provide by joining the International Foundation as a member, signing up for training and certification courses, making other purchases, or filling in other forms on the Sites. This includes information provided at the time of requesting further information or reporting a problem with the Sites.
• User profile information provided at the time of registering to use the Sites and throughout the period when you are logged onto the Sites.
• Your voluntary responses to surveys that we might ask you to complete.
• Details of transactions you carry out through the Sites and of the fulfillment of your orders.
• Your search queries on the Sites.
• Records and copies of your communications when you contact us.

Please remember that if you post any of your personal information in public areas of the Sites, such as in online communities or by posting a resume, such information may be collected and used by third parties over whom the International Foundation has no control. The International Foundation is not responsible or liable for any other third party's use of information that you submit to public areas and communities of the Sites, and the International Foundation cannot prevent third parties from retaining or using information that you post publicly.

B. Information We Collect Automatically

As you navigate through and interact with the Sites, we may use automatic data collection technologies to collect certain information, including:

• Usage details. When you access and use the Sites, we may automatically collect certain details of your access to and use of the Sites, including traffic data, approximate location data, logs, and other communication data and the resources that you access and use on or through the Sites.
• Device information. We may collect information internet connection and the equipment you use to access the Sites; IP address, approximate location, and other unique device identifiers; your activity on the Sites; and other usage details collected through your use of the Sites.

The information we collect automatically may include personal information, or we may maintain it or may associate it with other personal or business information we collect in other ways or receive from third parties. This information helps us to improve our Sites and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Sites according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Sites.

To allow the Sites to work properly and to provide you with a personalized experience, we sometimes place cookies on your device. A cookie is a small file containing a string of characters that is sent to your browser when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences, and other information, such as what pages you visit, your IP address, or how you arrived on the website. Ultimately, a cookie allows us or a third party to recognize you and make the Sites more useful to you. Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your browser.

We use both persistent and session cookies. Additionally, we use both first-party cookies (set by us) and third-party cookies (set by third-party service providers). Third-party cookies are cookies provided by our third-party service providers.

Below is a detailed description of the types of cookies we use on the Sites and the purposes for which we use the cookies.

• Essential Cookies. These cookies are essential for the Sites to function and cannot be switched off in our systems. You can set your browser to block or alert you about these cookies, but some parts of the Sites may then be inaccessible or not function properly. These cookies do not store any personal information^.
• Preference Cookies. These cookies enable us to provide enhanced functionality and personalization, as they remember choices you have made in the past, such as your username and password, or what language you prefer.
• Performance Cookies. These cookies collect information about how you use the Sites, like which pages you visit and which links you click on, and help us record and debug any issues you may have with the Sites. The purpose of performance cookies is to improve how the Sites function and to help us understand the traffic on the Sites.
• Marketing Cookies. We use these cookies to deliver advertisements, to make advertisements more relevant and meaningful to you, and to track the efficiency of our advertising campaigns. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites.

As indicated above, we may use third-party cookies and other third-party tracking technologies from third-party analytics providers to help us market, troubleshoot, and provide information about our products and services. We use analytics tools provided by third parties including, but not limited to Eloqua, Google Analytics and Google Ads, LinkedIn, NextRoll, CrazyEgg and ZoomInfo.

Upon your first visit to the Sites, you will receive a notification banner that allows you to select your preferences regarding cookies. If you close the banner, no cookies will be dropped, and the banner will not reappear.

You are also able to manually manage your cookies, delete cookies, or instruct your browser to refuse, delete, or disable cookies. Please visit the help pages of your browser for more information.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some parts of the Sites may then be inaccessible or not function properly.

C. From Third Parties

We may also receive personal information or draw inferences about you from other sources, including, without limitation, service providers who collect or process information on our behalf.

5. How We Use Your Personal Information

We may use the personal information that we collect about you or that you provide to us:

• To provide you with the Sites, all related content, and any other information, products, or services that you request from us.
• To create, manage, maintain, and secure your membership and account and to provide you with notices about your membership and account.
• To communicate with you and to process your requests, purchases, and payments.
• To notify you of changes or additions to any products or services we offer.
• To market to you and notify you of changes or additions to any products or services we offer, including to customize your experience and provide you with targeted advertising based on your online activity and inferred interests.
• To help maintain the safety, security, and integrity of the Sites, as well as our products, services, databases, and other technology assets.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• For testing, research, analysis, and product development, including to understand our audience, develop and improve the Sites, as well as our customer service, products, and services.
• To respond to law enforcement requests and, as required by applicable law, court order or governmental regulations.
• To evaluate, negotiate, or conduct an actual or proposed merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users and customers is among the assets transferred.
• To fulfill any other purpose for which you provide it.
• For any other purpose with your consent.

We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws or until you withdraw your consent (where applicable). To determine the appropriate retention period for your personal information, 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 use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Disclosure of Your Information

• To our subsidiaries and affiliates.
• To contractors, service providers, advisors, and other third parties we use to support our business and who use it only for the purposes for which we disclose it to them.
• To marketing providers that help us target advertisements to individuals who may be interested in learning more about our Sites and who help us supplement personal information we already have about you.
• To an actual or prospective buyer or other successor in the event of an actual or proposed merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the International Foundation, our members, or others.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction.

7. Your Privacy Rights

We provide all users with rights to:

• Confirm whether we process their personal information.
• Access, correct, and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.
• Opt-out of certain types of profiling.
• Limit our use of cookies.
• Withdraw your consent to our collection, use, and disclosure of your personal information.

To exercise any of these rights, please contact us using the information set forth in Section 12 (How to Contact Us) below. Please provide sufficient information that allows us to reasonably verify that you are the same person we have collected personal information about or are an authorized representative of such person. We may deny a request to change information if we cannot verify your identity or if we believe the change would violate any law or legal requirement or cause the information to be incorrect, and we may retain copies of your personal information to the extent required by applicable law.

To appeal a decision regarding a privacy rights request, please contact us as set forth in Section 12 (How to Contact Us).

8. Other Privacy Choices

We strive to provide you with as many choices as possible regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Account Access. You can review, change, and remove some of your personal information by logging onto the Site(s) and visiting your account profile page. You may also contact us as provided in Section 12 (How to Contact Us) to update your information.
• Tracking Technologies. You can refuse or disable cookies, whether by initially refusing cookies when you visit the Services or by setting your browser to refuse, delete, or disable all or some browser cookies, or to alert you when cookies are being sent. If you refuse, delete, or disable cookies, some parts of the Sites may then be inaccessible or not function properly.
• Device Permissions. Mobile devices offer permission systems for specific types of device data and notifications, such as phone contacts, pictures, location, and push notifications. You can change your settings on your device to either consent to or refuse the collection or processing of the corresponding information or the display of the corresponding notifications. If you disable or refuse certain permissions, the Sites may then be inaccessible or not function properly.
• Google Analytics. You can opt out of having your activity available to Google Analytics by installing the Google Analytics opt-out add-on. For more information, visit https://tools.google.com/dlpage/gaoptout.
• Promotional Offers from Us. If you do not wish to have your contact information used by us for promotions, you can opt-out by unsubscribing from any emails you receive from us. Additionally, you can also always opt-out by contacting us as provided in Section 12 (How to Contact Us).

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website, https://thenai.org/opt-out. Similarly, you can opt-out of receiving targeted ads from members of the Digital Advertising Alliance ("DAA") on the DAA's website, https://www.privacyrights.info. Canada residents can opt-out through the Digital Advertising Alliance of Canada Opt-Out Tool, https://youradchoices.ca/en/tools.

If you are a resident of certain jurisdictions (e.g., Canada), you may have additional rights and choices regarding your personal information. Please see Section 13 (Notice for Nevada Residents) and Section 14 (Notice for Canadian Residents) for additional information.

9. Security

We implement various physical, administrative, and technical safeguards in accordance with industry standards to protect the security of your personal information both online and offline. However, the safety and security of your information also depends on you. Where you have a password for access to certain parts of the Sites, you are responsible for keeping this password confidential. Please do not share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as the law in your jurisdiction. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. We will continue to protect your personal information in accordance with this Policy, and whenever we engage a service provider, we seek to require that its privacy and security standards adhere to this Policy and all applicable privacy law. By submitting your personal information or engaging with the Sites, you consent to this transfer, storage, or processing.

10. Children's Privacy

The Sites are not directed to nor intended for use by children under 18 years old (a "Child" or "Children"). We do not knowingly collect personal information from Children. Children are not authorized to use the Sites. If you are a Child, please do not use the Sites or provide any personal information to, on, or through the Sites. If we learn we have collected or received personal information from a Child, we will delete that information. If you believe we might have any information from or about a Child, please contact us by any of the methods listed in Section 12 (How to Contact Us).

11. Changes to this Policy

We reserve the right to review and revise this Policy from time to time, without prior notice, subject to any applicable legal requirements to notify you or obtain your consent. The date this Policy was last reviewed or revised is noted at the top of the page. You are responsible for periodically visiting this Policy to check for any changes. Your continued use of the Sites following the posting of changes constitutes your acceptance of such changes.

12. How to Contact Us

To exercise your privacy rights, ask questions, or comment about this Policy and our privacy practices, you may contact us:

• Via mail at International Foundation of Employee Benefit Plans, 18700 W Bluemound Road, Brookfield, WI 53045 United States or P.O. Box 2406, Postal Station A, Toronto, ON M5W 2K6, Canada;
• (888) 334-3327 (US) or (833) 886-3749 (Canada)
• Via email at [email protected]; or
• By visiting https://www.ifebp.org/column-3/contact-us
  

13. Notice for Nevada Residents

This Section 13 applies exclusively to visitors and users of the Sites who reside in the state of Nevada. Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada residents who wish to exercise this sale opt-out right may email us at [email protected]. Please include "Nevada" in your email subject line and include the following information in your email: (i) your name, (ii) Nevada resident address, and (iii) email address. However, please know we do not currently sell data triggering that statute's opt-out requirements.

14. Notice for Canadian Residents

This Section 14 (Notice for Canadian Residents) applies exclusively to visitors and users of the Sites who reside in Canada. We provide this Notice to comply with Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act ("PIPEDA"). We strive to protect your privacy by following each of the fair information principles set out by PIPEDA.

We recognize that we are responsible for personal information under our control. We have designated our CEO as our privacy officer to ensure privacy compliance, including PIPEDA compliance. If you have any concerns about our privacy practices and policies, you can contact our CEO at [email protected]. We will investigate any complaints received and try to substantively respond within 30 days of its receipt. If we need more time, we will inform you of the reason and extension period.

If our CEO is unable to resolve your concern, you may also contact the Office of the Privacy Commissioner of Canada.