Updated: September 2020
National Association of Wholesaler-Distributors (the “Company,” “we,” or “us”), dba Modern Distribution Management and MDM Analytics, believes you should always know what information we collect from you and how we use it, and that you should have meaningful control over both. This Privacy Policy (“Policy”) describes the privacy practices of the Company, including how it collects and processes the personally identifiable information (PII) you share with us when you access and use our websites, applications, products, events, services and other offerings (“Services”), and the rights and choices available to you regarding such information.
By using our Services, you consent to our collection, use and sharing of your PII as described in this policy. In some cases, we may ask you to provide explicit consent to receive information before we are able to send it to you.
Information We Collect
We collect personally identifiable information (PII) in the course of your use of our Services. The information we collect includes information you provide us when you subscribe or register for our products, services, events or offerings.
We, our partners, advertising networks and other third party service providers may also collect information when you visit our web pages, open our emails or engage with our products or services. This may include such information as your IP address, your operating system, your browser ID, other information about how you interact with the services, and your navigation patterns.
We may share data, such as hashed email derived from emails or other online identifiers collected on our site with advertising partners. This allows our partners to recognize and deliver you ads across devices and browsers.
We and other third party service providers, also use various technologies to collect and store information when you use the Services, including cookies and similar tracking technologies, such as pixels and web beacons, to analyze trends, administer the Services, track users’ movement around the Services, and identify ways to improve the Services and determine how we can make the Services a more positive and relevant user experience.
For additional information on how we use cookies and other tracking technologies, as well as how to opt-out of the use of cookies, please see our Cookies Statement. You can reject some or all cookies we use by changing your browser settings. However, doing so can impair the use of the Services or some of its features.
How We Use Your Information
We use the information we collect to improve our services and the user experience, send you information on product and services we believe may be of interest to you, and for network management and security. Specific use purposes are outlined below:
- To communicate with you by sending emails, which may include news, updates and information about the Company’s Services when you request them or when we believe they may be of interest to you. You will always have the opportunity to opt-out of receiving communications from the Company or elect to receive only certain communications by following the instructions provided in the email;
- To provide you with third-party services and products information that we believe may be of interest to you. You will always have the opportunity to opt-out of receiving communications from us or elect to receive only certain communications by following the instructions provided in the email;
- To process transactions, including payment transactions, when necessary to fulfill orders;
- To effectively respond to customer service requests and support needs, including responding to inquiries, diagnosing problems with the Site and Services, and other customer care and support;
- To personalize your experience as your Personal Information helps us better respond to your individual needs;
- To improve the Services we offer, including maintaining and improving the performance of the Services, developing new features and capabilities, producing effort reports to improve functioning, using search queries and clicks to improve the relevance of your search results and using data to determine what new features to prioritize;
- To research and analyze the Services’ users’ demographics, interests, and behavior in an aggregated form, including to improve our Services and to improve the Services and its offerings. Where applicable law requires consent to use certain cookies, we will ask for your consent; and
- For legal, security, safety, and dispute resolution, including detecting and preventing fraud, resolving disputes and enforcing agreements.
We do not sell, rent, exchange, or transfer your PII to any other company or third party without your consent unless for the express purpose of delivering the products or services requested.
We do use third-party vendors to carry out certain services such as website management, hosting, and online purchase and credit card processing. We will only share your PII with third-party vendors that provide services on our behalf for the purposes described in this Policy. In such case, your PII will be shared only for the limited purpose of performing the services on our behalf and under our instruction and in accordance with this policy.
Your information is also being used for our own marketing purposes. We use third party technologies to help us recognize your device and understand how to use our site so that we can improve our services to reflect your interests and serve you advertisements about the products/services that are likely to be of more interest to you. Our advertising partners collect information about your activity to enable us to:
- Measure and analyze traffic and browsing activity on our site
- Show advertisements for products and services to you on third-party sites
- Measure and analyze the performance of our advertising campaigns.
Third Party Analytics and Advertisers
We use automated devices and applications, such as Google Analytics, to evaluate usage of our site and our Services. Visitors can opt-out of Google Analytics for display advertising and customize Google display network ads using the Ads Settings here.
We use third parties to serve advertisements, including advertisements based on online behavior. Third parties may place and use tracking mechanisms (e.g., tracking pixels) on our web pages or in the emails we send you. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including Pixel Tags or clear GIFs) and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.
Data Retention/Security
Your Personally Identifiable Information is stored on the servers of our service providers and vendors. These are located in Canada, Malta, the Netherlands, the United Kingdom, and the United States.
We will retain your PII for as long as you maintain an account with the Company, or as otherwise necessary to provide you the Company’s Services. We will also retain your PII where necessary to comply with legal obligations, resolve disputes, or enforce agreements. When we no longer need the information for the purposes outlined in this Policy, we will delete your PII.
We take every precaution to protect your PII against accidental loss and from unauthorized access, use, alteration, and disclosure.
Children should always get permission from their parents before sending any information about themselves over the Internet. We do not knowingly collect or receive personal data from children under 13 years of age. If we learn we have received Personally Identifiable Information from a child, we will delete the data.
We restrict access to your PII to those employees of the Company who need to know that information to provide services to you. We train those employees about the importance of confidentiality and maintaining the privacy and security of your information. Service Providers and vendors have access to PII to perform their functions but may not use it for other purposes.
However, despite our efforts, no security controls are 100% effective, and we cannot ensure or warrant the security of the Personally Identifiable Information you provide to us. There is no guarantee that the data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
The Services may, from time to time, contain links to other websites. If you follow a link to any of these websites, please note that they may have their own privacy policies and that we do not accept any responsibility or liability for these policies or websites. Please check these privacy policies before you submit any PII. This Policy applies only to information collected by the Services and by us and not to other websites that you may link to from here.
We use SSL security on any form that requires credit-card or debit-card information. We will never ask for information that could be used in a phishing scheme without the SSL security behind the form.
Disclosures of Personal Information
As mentioned above, we may disclose your Personally Identifiable Information to selected third parties associated with payment processing, website administration and our own marketing, including ad retargeting. These third parties are contractually bound to use PII only to perform the services that we hire them to provide.
In addition, we may ask you to provide personal information to access sponsored content, includes whitepapers, webcasts and other products or services. When accessing this content, your PII may be shared with those third parties, and the information will be governed by their privacy policy. We do not bear any responsibility for the actions or policies of these third parties.
We use service providers and vendors to process PII in the following countries: Canada, Malta, the Netherlands, the United Kingdom, and the United States. Data protection and privacy laws in these countries may offer a lower level of protection than in your country and/or region.
Personally Identifiable Information collected within the EEA will be transferred to countries outside of the EEA for the purposes described in this Policy. We rely on derogations outlined in Article 49 of the General Data Protection Regulation to transfer PII outside of the EEA. In particular, we transfer it out of the EEA with your consent or to perform a contract with you. We apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Policy. By providing your Personally Identifiable Information to us, you are consenting to the transfer, storing, and processing of your personal information outside of the EEA.
Accessing and Updating Personal Information
You may view and update the information we have about you by sending us an email at info@mdm.com. We will deliver the personal information that we are required by law to disclose within 45 days after receipt of a verifiable request, unless we notify you that we require additional time. You have the right to request that we delete PII that we have collected from you.
Opt-Out
You may opt-out of our email marketing lists by following the directions at the bottom of our emails. Please note that MDM has a number of brands and products and we allow you to opt-out selectively. To remove a specific email address from all of MDM’s marketing communications, you may send a request info@mdm.com. If you wish to remove your email address only from a specific brand, please use the opt-out mechanism provided in emails you receive from such brand or contact the brand directly.
You may receive email marketing messages from us about other companies’ offerings as part of a business partner marketing program. To opt-out of a business partner marketing email program, you may follow the instructions at the bottom of any email we send you as part of the program.
We and other third party service providers, also use various technologies to collect and store information when you use the Services, including cookies and similar tracking technologies, to administer the Services and track users’ movement around the Services. For additional information on how we use cookies and other tracking technologies, as well as how to opt-out of the use of cookies, please see our Cookies Statement.
Our partners may use non-cookie technologies that may not be impacted by browser settings that block cookies. To opt out of receiving these personalized ads or cross device tracking, the following third-party opt-out tools can be used for that purpose:
—DAA: http://www.aboutads.info/
—NAI: http://optout.networkadvertising.org/?c=1
—EDAA (Europe only): http://www.youronlinechoices.com/
Please note that this “opt-out” function is browser-specific and relies on an “opt-out cookie”, thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt-out again.
Please note that opting-out of promotional mailings will not affect delivery of your subscription-based products.
To remove a specific phone number or fax number from a specific brand’s marketing communications, please follow the opt-out directions provided during/in those communications. To remove a specific phone/fax number from all of MDM’s marketing communications, you may send a request to info@mdm.com.
If you are a resident of the EEA, you have certain rights concerning the collection, use, and storage of your Personally Identifiable Information. You are entitled to know what PII we collect about you and to have access to that information. You have the right to remove or correct any of your PII that is inaccurate, to object to certain processing, and to withdraw any consent you may have given us for any processing of your personal data. You may also request to have your PII deleted and to have us request that any third-party that has received your PII pursuant to an authorized purpose also cease to use or further disseminate your Personally Identifiable Information. You can exercise these rights by emailing us at info@mdm.com.
Your California Privacy Rights
In accordance with the California Consumer Privacy Act (CCPA), this section provides you with specific rights outlined in the legislation and includes information on how to exercise those rights.
Right of Access
You have the right to request that MDM provide you with certain information pertaining to our collection and use of your Personally Identifiable Information over the past 12 months. Once we receive your verifiable consumer request, we will disclose to you:
- The categories (and specific pieces) of information MDM has collected about you.
- The categories of sources for the PII that MDM has collected about you.
- Our business purpose for collecting and/or selling the PII about you.
- The categories of third parties with whom we may share that information.
- If we sold or disclosed your Personally Identifiable Information for a business purpose, we will disclose to you the categories of your PII that MDM has sold/disclosed.
Right to Deletion
You may also request that MDM delete any Personally Identifiable Information that we have about you.To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
-Calling us at 1-202-872-0885
-Emailing us at: info@mdm.com
You may only make a verifiable request for access to your Personally Identifiable Information twice within a 12-month period. In order for MDM to respond to your request or provide you with PII, the verifiable consumer request must:
- Provide enough information for us to reasonably verify that you are the person about who Personally Identifiable Information was collected.
- Include sufficient detail in the description of your request so that we can properly understand, evaluate, and respond to it.
We will only use the Personally Identifiable Information provided in the verifiable customer request to verify the requestor’s identity.
Right to Non-Discrimination
MDM will not discriminate against you for exercising your CCPA rights. You will not be:
- Denied goods or services.
- Charged different pricing/rates for goods and services or suggest that you will be charged different pricing/rates for goods and services.
- Provided with a sub-standard quality of goods and services or suggest that you will be provided with a sub-standard quality of goods and services.
“Do Not Sell My Personal Information” Request
CCPA law requires that MDM maintain a separate web page where you can choose to opt out of the sale of your PII, which can be accessed by clicking the link below:
You may also contact us by phone to make this request by calling 1-202-872-0885.
Categories and Sources of Personally Identifiable Information Collected
MDM is required by CCPA to provide details of the categories of personal information collected, and the sources of that personal information collection, within the last 12 months.
Use of Personally Identifiable Information
MDM is also required by CCPA to provide details on the purposes of collecting your personal information.
Information Sold or Disclosed for Business Purposes
MDM has sold the following categories of Personally Identifiable Information in the last 12 months: Identifiers (contact information) including name, postal address, phone number, email address; and business classifications such as “Company Type”, “Job Title”, and “Job Function”.
Additionally, we utilize trusted third parties to provide services and perform functions for us, including maintenance and hosting, database storage and management, registration processing, and direct marketing campaign processing. Your PII may be shared with these third parties to the extent necessary to provide the services and perform the functions mentioned.
Mobile Devices
Mobile marketing campaigns may involve your sending an email from your mobile device to MDM or a third-party campaign operator. An email or other response will then be sent to your mobile device. Opting to participate in this type of campaign is your choice. When you engage in these mobile marketing campaigns, MDM and the third-party campaign operator may collect and use your cell phone number, the name of your wireless service provider, images that you send using your cell phone as part of the campaign, and other relevant information.
Users Outside the US
Our websites are operated in the United States. If you are located in the European Union or outside of the United States, be aware that any information you provide us will be transferred to the United States. By using our Services, you consent to this transfer and to our collection and use of your information as set forth above.
Privacy Policy Updates
We may change this Privacy Policy at any time. Any adjustments to the policy will be posted on this website and will serve as your notification of these changes. By continuing to use our site and/or our Services, you agree that you will be deemed to have agreed to be bound by the Privacy Policy as changed.
Other
We reserve the right to share your Personally Identifiable Information when we believe that such disclosure is necessary to comply with a legal requirement, such as a court order, valid discovery requests, valid subpoena, or to protect the rights or property of the Company, you, or third parties, and if we are acquired in a merger or acquisition.
Questions?
If you have a privacy question, concern, or request, please contact us at: info@mdm.com or at the following address:
National Association of Wholesaler-Distributors
1325 G St NW Suite #1000
Washington DC 20005
