Who We Are

This Privacy Policy applies to The Atlantic Council of the United States (“we” or “us”) owned and operated websites and its subdomains (“Sites”).

Who You Are

Visitor. You may be a visitor to our Sites and either provide us with your data or you may contact us through our Sites seeking information about our publications, blogs, events and event registration.

By accessing or using our Sites or communicating with us outside of our Sites you are accepting and consenting to the practices described in this Privacy Policy, which may be updated and amended from time to time. If you do not agree to the terms of this Privacy Policy, you must not access or use our Sites or our Services or otherwise communicate with us.

Your Privacy Matters

We are responsible for determining the purpose and means of processing any Personal Data about you during your visit to our Sites. We know that you care how your data is used and shared. This Privacy Policy is designed to help you understand our privacy practices and the choices available to you when you visit our Sites. Please contact us at [email protected] if you have any questions.

This Privacy Policy describes how we protect your Personal Data, which is defined by the European Union, the U.S. government and many U.S. states in similar yet unique ways. For the purposes of our Sites, we define “Personal Data” to be information that can be used to identify a person directly or indirectly and can include a name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, log in account number and associated password, date of birth, government-issued credentials (e.g., driver’s license number, national ID, passport, Social Security number and Taxpayer ID), an IP address, location data or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

When this Privacy Policy Applies

This Privacy Policy explains what Personal Data we collect when you access our Sites, how the Personal Data will be used, and how you can control the collection, correction or deletion of that data.

We will not use or share your Personal Data with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to data we collect by other means including offline or from other sources. The use of Personal Data collected through our Sites is limited to the purposes set out in this Privacy Policy.

We will process and store your Personal Data only for the period necessary to achieve the purpose of collection or as long as required by applicable law. Our legal basis for processing your Personal Data is your consent as indicated on our Sites or that the processing is necessary for the performance of a contract to which you are party with us.

Data You Share with Us

We may collect Personal Data when you visit our Sites such as information related to your online device, including your IP address, referring website, what pages your device visited, and the time your device visited our Sites. For more information on this, see information below relating to Cookies.

If you choose to donate through our Sites, we or our third-party payment processors will collect your payment information.

We send newsletters through email; and we may send emails relating to our events and events’ registration. If you no longer wish to receive these emails, you may opt out of them by clicking the unsubscribe link in the email communications we send.

How We Use Your Personal Data

We use your Personal Data when you visit our Sites for the following purposes:

  • To administer our Sites and for internal operations, including troubleshooting, data analysis, testing, statistical and survey processes.
  • To improve our Sites to ensure that content is presented in the most effective manner for you and your device.
  • As part of our efforts to keep our Sites safe and secure.
  • To arrange opt-in subscriptions; to deliver email newsletter; to deliver content to enable events’ registrations.

We may also use your Personal Data to contact you via email, and other means, regarding new publications or events we think may be of interest to you if this is in accordance with your emailing preferences.

Legal Basis for Processing within European Economic Area (EEA) only

If you are an individual from the European Economic Area (EEA), our legal basis for collecting and using the Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where: (a) we have your consent to do so, (b) where we need the Personal Data to perform a contract with you, or (c) where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

Where we rely on your consent to process the Personal Data, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our (or a third party’s) legitimate interests which are not already described in this Privacy Notice, we will make clear to you at the relevant time what those legitimate interests are.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided further below.

Cookies and Tracking

Technology

Cookies are small pieces of data sent by a website to a visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. We and our authorized partners may use cookies and other data gathering technologies for a variety of purposes. These technologies may provide us with Personal Data, information about devices and networks you utilize to access our Sites, and other Personal Data regarding your interactions with our Sites. For detailed information about the use of cookies in our Sites please read and review our Cookie Policy.

We partner with third parties to manage our advertising on other sites. Our third-party partners may also use technologies such as cookies to gather Personal Data about your activities on our Sites and other sites in order to suggest advertisements based upon your browsing activities and interests.

Web beacons, tags and scripts may be used on our Sites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Sites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

We use Local Storage Objects (“LSOs”) such as HTML5 to store content Personal Data and preferences. Various browsers may offer their own management tools for removing LSOs. Third parties with whom we partner to provide certain features on our Sites based upon your Web browsing activity use LSOs and Flash to collect and store Personal Data. For further information on how to manage Flash LSOs please click here.

Logs

We gather certain data and store it in log files when you interact with our Sites. This data includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, data you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration data. Occasionally, we connect Personal Data to data gathered in our log files as necessary to improve our Sites. In such a case, we would treat the combined data in accordance with this Privacy Policy.

Analytics Tools

Our Sites use analytics tools to track user activity, page content, and click/touch. Please read our Cookie Policy to learn more about our use of analytics tools and your options to opt-out of data collection by analytics tools and similar technologies.

Data from Third-Party Services

Social Media Widgets

Our Sites include social media features, such as the Facebook Like button and other widgets. These features may collect your IP address and which page you are visiting on our Sites and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly by us. Your interactions with these features are governed by the privacy policy of the organization providing it. Please read our Cookie Policy to learn more about Social Media Widgets.

When We Share Your Personal Data with Third Parties

We will not rent or sell your Personal Data to others unless otherwise identified in this Privacy Policy.

Vendors, Consultants and other types of Processors. We may share your Personal Data with Atlantic Council’s Processors such as vendors or consultants who are engaged to perform tasks on our behalf. These Processors include, for example, our payment processing providers, help desk software providers, email service providers and others. These companies do not retain, share, store or use Personal Data for any other purposes.

Your Anonymous Data. We may share data that is not Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties. This data may be stored indefinitely.

Legal Disclosures. We will disclose your data where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) to enforce our contractual rights or to protect the security or integrity of our business, and/or (iii) to exercise or protect the rights, property, or personal safety of us, our users or others.

Transfer of Possession of Your Data. You will be notified via email and/or a prominent notice on our Sites of any change in possession or uses of your Personal Data, as well as any choices you may have regarding your Personal Data.

Where We Store and Process Your Personal Data

Location. Your Personal Data may be stored and processed in the United States, Europe, or any other country in which we, our subsidiaries, affiliates or service providers maintain facilities. We may transfer your Personal Data to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we will not transfer data, including Personal Data, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. We will always protect your Personal Data in accordance with this Privacy Policy regardless of where it is processed.

Our Sites are hosted in the United States of America and are subject to U.S. state and federal law. If you are accessing our Sites from other jurisdictions, please be advised that you are transferring your Personal Data to us in the United States, and by using our Sites, you consent to that transfer and use of your Personal Data in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of our Sites and your agreements with us. Any persons accessing our Sites from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use our Sites in a manner lawful in their jurisdiction. If your use of our Sites would be unlawful in your jurisdiction, you may not use our Sites.

How We Protect Your Personal Data

Security. We are concerned with protecting Personal Data and use appropriate technical, organizational and administrative measures to protect the Personal Data we hold in our records from unauthorized access, loss, misuse, disclosure, alteration or destruction. However, no method of transmission over the internet, method of electronic storage, or process that is subject to human error is 100% secure.

Security Incident. In the event that your Personal Data is compromised as a breach of security, we will notify you in compliance with applicable law.

Your Rights

General Rights. You can always decide not to disclose your Personal Data to us, but that may limit your ability to take advantage of some of the features of our Sites. You can opt-out of receiving communications from us at any time by using the unsubscribe link in the email communications we send. We may still send you communications related to our business and/or your transactions with us.

You can exercise these and any of the following rights to your Personal Data by contacting us at [email protected] and we will respond in a reasonable time in accordance with applicable law.

Access. You have a right to access your Personal Data held by us. We may charge for a request for access in accordance with applicable law.

Amendment. You have the right to request that we update any inaccurate Personal Data. To update your Personal Data, you may contact us at the email address set forth above.

Withdrawal of Consent. Where we process Personal Data based on consent, you have a right to withdraw consent at any time.

Right to Erasure (Right to be Forgotten). In certain circumstances, you may have a broader right to erasure of Personal Data that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain data for record keeping purposes, to complete transactions or to comply with our legal obligations.

Right to Restrict Processing. You may have the right to request that we restrict processing of your Personal Data in certain circumstances (for example, where you believe that the Personal Data we hold about you is inaccurate or unlawfully held or your Personal Data is no longer needed for the purposes of processing but you require the data for exercise or defense of a legal claim).

Right to Object to Processing. You have the right to object to our processing of your Personal Data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Data Portability. In certain circumstances, you may have the right to be provided with your Personal Data in a structured, machine readable and commonly used format and to request that we transfer the Personal Data to another data controller without hindrance.

Complaints. We hope that you won’t ever need to, but you can complain about our use of your Personal Data. We will investigate and respond to you. You also have the right to lodge a complaint with the supervisory authority responsible for data protection in the EU member state or the state attorney general in the country or US state of residence, your place of work or the place of the alleged infringement.

Please remember that we may still use any aggregated and de-identified Personal Data that does not identify you and may also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Children and Our Services

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit Personal Data from anyone under the age of 16, located/residing within the European Union. In the event that we learn that we have collected Personal Data from a child under age 16 located/residing within the European Union, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under 16 located/residing within the European Union, please contact us at [email protected].

Notification Procedures

It is our policy to provide notifications, whether such notifications are required by law or are for other business-related purposes, to you via email, written or hard copy notice, as determined by us in our sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt-out of certain means of notification as described in this Privacy Policy.

Links to Other Web Sites

We are not responsible for the practices employed by websites or services linked to or from our Services or our Sites, including the data or content contained therein. Please remember that when you use a link to go from our Sites to another website or service, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies.

Do Not Track Disclosure

“Do Not Track” (“DNT”) refers to an HTTP header used by Internet web browsers to request a web application disable its tracking or cross-site user tracking. When DNT is enabled, a user’s web browser adds a header to content requests indicating that the user does not want to be tracked. Some U.S. state laws require us to disclose how we respond to web browser DNT signals.

At this time, we do not respond to or take any action with respect to a DNT configuration set in your internet browser, and therefore, do not disable tracking. For data about Do Not Track, visit www.allaboutdnt.org.

In addition, we deploy cookies, tracking pixels, web beacons, and other technologies on our websites. Those tools may be used by us or third parties to collect data about you and your internet activity, even if you have turned on the Do Not Track signal. Please read our Cookie Policy to learn more about tracking of your online activities.

Changes to Our Privacy Policy

All changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our Sites, prior to the change becoming effective and update the ‘effective date’ at the top of this page.

Contact Us for Any Reason

If you have any questions about this Privacy Policy, please contact us at:
Privacy Officer: Julie Varghese
Email: [email protected]
Phone: +1 202 599 8637
Address: 1030 15th Street, NW, 12th Floor, Washington, DC 20005

Last Updated: September 9, 2019