What is Personal Information?
Miller Tanner Associates defines personal information as information that identifies an individual or that can be reasonably associated with a specific person or entity, such as a name, contact information, Internet (IP) address. Miller Tanner Associates collects personal information to facilitate an individual’s event-specific requirements (e.g. travel itinerary, dietary restrictions) and/or training details (e.g. training progress, assessment score) within our web-based learning management system.
Participation in Privacy Shield
Miller Tanner Associates complies with the Privacy Shield Principles for all onward transfers of personal data from the European Union, the United Kingdom and Switzerland pursuant to the privacy shield, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Miller Tanner Associates is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
In compliance with the EU-US and Swiss-US Privacy Shield Principles, Miller Tanner Associates commits to resolve complaints about your privacy and our collection or use of your personal information. European Union, United Kingdom or Swiss individuals with inquiries or complaints regarding this Privacy Statement should first contact Miller Tanner Associates’ Privacy Administrator at the address located below in the Questions or Concerns section.
Miller Tanner Associates has further committed to refer unresolved privacy complaints from EU and Swiss individuals pursuant to the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by BBB National Programs, Inc.
If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
If your Privacy Shield complaint cannot be resolved through these channels, you may complain to your home data protection authority and as a last resort, may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm Contact details for the Swiss Federal Data Protection and Information Commissioner can be found at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html
California Consumer Privacy Act Statement
The California Consumer Privacy Act (CCPA) entitles California residents with specific rights regarding the sale and/or usage of their personal data. Miller Tanner Associates does not currently, nor has at any time, sold personal data. To learn more about the data that Miller Tanner Associates does collect please see the following sections below: Miller Tanner Associates’ Collection of Personal Information, Use of Personal Information, Sharing of Personal Information, Other Uses and Disclosures, Protection of Personal Data and Access.
Collection of Personal Information
We collect the personal information that you provide us, such as when you:
- Register for an event that Miller Tanner Associates has been contracted to manage
- Register for an account within our learning management system
- Voluntarily provide feedback, via a questionnaire, for an event.
- Sign up to receive marketing materials from Miller Tanner Associates. You may opt-out of these communications at any time.
- Submit forms for event-specific reimbursements (where applicable)
- When you contact us for any reason
We may automatically collect some information when you visit our website, such as your computer’s IP address and operating system, the site from which you linked to us, your site activity, the time and date of your visit. This information may be collected through the use of “cookies” and web beacons (see Online Specifics below).
- Information Gathering and Use
Like most web sites, our servers log your IP address, the URL from which you accessed our site, your browser type, and the date and time of your purchases and other activities. We use this information for system administration, troubleshooting, and the investigation of security incidents.
Your browser will accept cookies and allow automatic collection of information unless you change the browser default settings. If cookies are disabled, the web site will not load properly
Use of Personal Information by Miller Tanner Associates
The personal information we collect is limited to what is necessary in order to process your event or training registration, coordinate travel or accommodations on your behalf, provide you with high-quality service, and administer your account, including distribution of our post-event surveys and/or to provide payment for services or reimbursements. For example, we may:
- Notify you about your itinerary or relevant event information. This may include changes to aforementioned information.
- Contact you for your feedback about the event you attended and the service that was provided.
Sharing of Personal Information
We share information in these circumstances:
- Registration Fulfillment
- We may provide information to a third party as necessary to fulfill an event registration that you completed with us. For example, we may provide your contact information to a travel agency, and a ground transportation company to ensure safe travel between your point of origin, the airport and the event venue. However, we give suppliers, and others involved in the travel and accommodation chain only the information needed to provide you the services you require, and we have a contractual agreement with such vendors requiring them to keep the information confidential and not to use it for other purposes. Please note that if you provide health information during registration, such as dietary or special needs, Miller Tanner Associates must share this information with certain third parties to act on your request. We are not responsible for any information you provide directly to these parties. Transfers of personal data to third parties who assist Miller Tanner Associates in providing the services that you request (e.g. hotels, car rentals, airlines, Visa applications, client reports) may be located in non-European Union jurisdictions which may not provide an equivalent level of protection.
- Transfer of Value
- Following the completion of an event, Miller Tanner Associates will provide reports and documents to the organization (e.g. Sponsor / CRO) that contracted Miller Tanner Associates for the event. These reports will include personal information and transfer of values related to the hospitality provided for you at the event.
- Our Contractors/Vendors
- We may contract with others to perform services on our behalf. For example, we might retain a company to print and or ship event materials, distribute emails, or process surveys. If any of these service providers need access to your personal information, we require them to use it only to perform the services for us. We also require that they maintain the confidentiality of the information while in their possession.
- Individuals Employed by our Vendors
- If you are a vendor engaged by us, or if you are employed or otherwise engaged by a vendor engaged by us, we may collect and otherwise process your name and company contact information where it is in our legitimate interest to: (i) manage our relationship with vendors; and (ii) perform, or to enter into, contracts with such vendors (for example to process payment details). We will have obtained your personal data from you, or from your employer.
- If you are a vendor, we ask that you provide this notice to your employees and other staff who have or have had dealings with us on your behalf.
Other Uses and Disclosures
In addition, we may use or disclose personal information in the good faith belief that we are lawfully authorized to do so, or that doing so is reasonably necessary to protect you, to comply with legal process or authorities, to respond to any claims, or to protect the rights, or personal safety of Miller Tanner Associates employees or the public.
Protection of Personal Information
We have physical, administrative and technical security measures in place to protect personal information from loss, misuse or alteration while it is under our control. Further, when you enter personal information online, that information is encrypted prior to transmission using a security protocol called SSL (Secure Sockets Layer) / TLS (Transport Layer Security).
Online account information is accessible only by using a password. You must keep your password confidential. You are responsible for all uses of Miller Tanner Associates internet properties (e.g. event.millertanner.com) and are advised not to share your password with anyone else. Please advise us immediately at firstname.lastname@example.org if you believe your password has been misused.
We acknowledge the right of EU and Swiss individuals to access their data pursuant to the Privacy Shield. If you wish to access, amend, or confirm that Miller Tanner Associates has personal data relating to you, or if you wish to correct or delete your Personal Information if it is inaccurate, please notify us at email@example.com. We will respond to your request within 30 days.
Please note that Miller Tanner Associates may not be able to delete information that has been shared prior to your request to remove or delete with third-parties contracted for event-related purposes (e.g. travel agency, hotels, ground transportation company).
We will always give you the opportunity to choose opt-out before your Personal Information is 1) disclosed to a third party (other than a Miller Tanner Associates agent doing work at our direction), or 2) to be used for a purpose that is materially different than that for which it was originally collected or subsequently authorized by you. Although we do not ever anticipate providing sensitive Personal Information, such as health information, to a non-contracted third party or using it for a purpose other than that for which it was collected, we will never do so without first allowing the individual involved to affirmatively and expressly consent (opt-in) to such transfer or use. The only exception to this choice for both sensitive and non-sensitive Personal Information would be where we are required to disclose your Personal Information pursuant to governmental or judicial order, law or regulation to meet national security or law enforcement requirements.
Questions or Concerns
Questions or Concerns
If you have any questions or concerns about this privacy statement or would like to contact us for any reason, you can do the following:
- Email us at firstname.lastname@example.org
- Write us at:
Miller Tanner Associates
Attention: Chief Compliance Officer
PO Box 41529
Memphis, TN 38103-4599
United States of America
Changes to this Statement
We may change this privacy statement at any time but will alert you that changes have been made by indicating at the top of the privacy statement the date it was last updated. We encourage you to review our privacy statement to make sure you understand how your personal information will be used. If we make a material change to how we use personal information and the new uses are unrelated to uses we disclose in this statement, we will communicate the changes in advance.
Updated 01 May 2020