Privacy Policy

The Kemper Old Boy Network

PRIVACY POLICY

(Cookie notice can be found here)

Last Updated: June 20, 2019

The Kemper Old Boy Network (KOBN) respects your privacy and is committed to protecting it through our compliance with this privacy policy. This privacy policy explains our policies and practices regarding the information we collect from and about you. It is through this privacy policy that we intend to provide you with a level of comfort and confidence in how we collect, use, and safeguard personal and other information we collect and obtain, or that you provide through https://kemperoldboy.com and our various other websites (collectively, the “Site”):

https://kemperoldboys.com

https://kemperoldboynetwork.com

and how you can contact us if you have any questions or concerns. It is our sincere hope that by explaining our data handling practices we will develop a trusting and long-lasting relationship with you.

For the purposes of the EU General Data Protection Regulation 2016/679 (the “GDPR”), The KOBN is the data controller. This means that we are responsible for deciding how we use the information that we hold. We are a 501(c)(3) non-profit organization registered in the United States with an office at:

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The GDPR applies to you if you reside in the European Economic Area (an “EEA Resident”)

Please note that by visiting or using the Site and the various other services, features, functions, software, applications, websites and networks provided by the KOBN (together with the Site, collectively, the “KOBN Services”), you are accepting the practices described in this privacy policy subject to any rights or restrictions that might apply under the GDPR if you are an EEA Resident, including the rights described in the European Privacy Rights for EEA Residents provisions below. This privacy policy is also incorporated by reference into the various other agreements and terms and conditions that govern your use of the Site and the other KOBN Services (collectively, the “Terms”).

This policy describes the types of information we may collect from you or that you may provide when you access or use the Site, the other KOBN Services or other features, functions, services products and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect or may collect:

In accessing and using the Site and the other KOBN Services.

In becoming a member of the KOBN.

In e-mail, text and other electronic messages sent through or use of the Site and the other KOBN Services.

When you interact with other users of the KOBN Services.

When you send any content through the Site or any of the other KOBN Services.

Through services provided to us or you by our affinity partners, third-party companies, agents or contractors.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by KOBN, any chapters or affiliates of KOBN or any third party; or Any third party, including through any application or content (including advertising) that may be accessible from or on the Site or any of the other KOBN Services.

Please read this policy carefully to understand our policies and practices regarding your personal data and how we will treat it. If you do not agree with our policies and practices, your only choice is not to use any of the KOBN Services. By accessing or using any of the KOBN Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Site and/or any of the other KOBN Services, after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. Nothing in the foregoing paragraph is intended to affect any rights that an EEA Resident might have or restrictions that apply, under the GDPR.

Minors under the Age of 13

None of the KOBN Services are intended for minors under 13 years of age. No one under age 13 may provide any information on or through the Site or the other KOBN Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the KOBN Services or any of its features or register on the Site use any of the interactive or public comment features of any of the KOBN Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at admin@kemperoldboy.com.

Information We Collect About You and How We Collect It

We collect or may collect several types of information from and about you and other users of the Site and the other KOBN Services, including:

Information by which you may be personally identified, such as your full name, address, birthdate and e-mail address, (“personal data”);

Financial and billing information, including credit card information;

Analytics information;

Information that is about you but individually does not identify you, such as IP address and date and time of visit;

Usage details and information, including how you communicate with other users of the KOBN Services;

Information contained in the comments and postings on or through any of the KOBN Services;

The device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number);

Geo-location information when you use the Site and the other KOBN Services;

Information that you provide by registering or filling in forms or applications on or through the Site and the other KOBN Services;

When you report a problem with the Site or any of the other KOBN Services;

Records and copies of your correspondence (including e-mail addresses), if you contact us;

Details of transactions you carry out through the Site and any of the other KOBN Services; and/or

Your search queries on or through any of KOBN Services.

We collect this information:

Directly from you when you provide it to us.

From the US Postal Services when we receive notices of address changes.

Automatically as you navigate through or use the Site and the other KOBN Services.

From third parties, such as our members, affinity and business partners and other third parties that provide us or you with certain services.

Certain web transactions may also involve you calling us or our calling you. Please be aware that we may monitor and in some cases record such calls for staff training or quality assurance purposes.

You may now or in the future participate in discussion boards, chat rooms and/or provide comments, pictures, audio and video recordings, text, data, information and other input or any other content linked, posted, and/or submitted by you or other users to be published or displayed (hereinafter, “posted”) on or through the Site or the other KOBN Services, or transmitted to third parties or other users of, the KOBN Services (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Site or the other KOBN Services, with whom your User Content is shared. Therefore, we cannot and do not guarantee that your User Content will not be viewed, downloaded or shared by unauthorized persons.

Use of Cookies and Other Tracking Technologies.

The technologies we use for automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.

Pixels and Tags. Pixels and tags are site instrumentation tools that help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. Emails or electronic newsletters we send may use tools (e.g., pixel tags or web beacons) to gather email metrics and information to improve the reader’s experience such as how many of the emails are opened, if they were printed or forwarded, the type of device (e.g., mobile or PC) from which they were opened, and the associated member account details, which include name, city, state, and county associated with the applicable IP address. In general, any electronic image viewed as part of a webpage, including an ad banner, can act as a web beacon.

Session Logs. Session logs help us determine how people travel through the Site. In this way, we can structure our pages so that the information most frequently visited is easier to find. By tracking page visits, we can also determine if the information we’re providing is being used. The only data gathered is the Internet Protocol (IP) address from which you came (which contains no personal data), the website that referred you, the pages you visited and the date and time of those visits.

Use of cookies is subject to our Cookie Notice located at http://kemperoldboy.com/cookie-notice.

Do Not Track Policy

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services.

Third-party Responsibilities and Services.

We may use or partner with KOBN chapters, affiliate partners and other third-parties, agents or contractors for various purposes in connection with our business and operations (collectively, “Service Providers”), including, credit card and deposit services, insurance services, travel services, relationship building, the marketing and growth of KOBN, the awarding of scholarships, volunteer programs and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your personal data. We may also share information, including your personal data, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. Many Services Providers have adopted their own privacy policies, which are not subject to control by KOBN. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of Service Providers, please email us at admin@kemperoldboy.com.

Service Providers that have access to your personally identifiable information in connection with providing services are required to keep your personal data confidential and are not permitted to use this personal data for any purpose other than to fulfill the services they are performing for KOBN or the Site.

The Service Providers may also transmit cookies to your computer or device when you click on ads that appear on or through the Service. Also, if you click on a link to a third-party website, such third party may also transmit cookies to you and we do not have any control over that. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any our Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.

Use of Remarketing with Google Adwords, Google Analytics and other Remarking and Analytic Services

We use or may in the future use a variety of remarketing and analytic services including:

Google Adwords

The Site uses Google AdWords to advertise on third party websites to previous visitors to our Site. It could mean that we advertise to previous visitors who haven’t completed a task on the Site, for example using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Site. Of course, any data collected will be used in accordance with this privacy policy, as well as Google’s privacy policy.

DoubleClick: We use “Google AdWords” remarketing codes to log when users view specific pages or take specific actions on the Site. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out or the Network Advertising Initiative opt-out.

Google Analytics

We use a tool called “Google Analytics” to collect information about the use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve the Site. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

How We Use Your Information

We will only use information that we collect about you or that you provide to us, including any personal data for purposes described in this Privacy Policy and when applicable law allows us to do so. We will generally use your information on the following legal grounds:

Where the use of your information is necessary for the performance of a contract we are about to enter into or have entered into with you;

Where the use is necessary for the purposes of our legitimate interests (or those of a third party);

Where we need to comply with a legal or regulatory obligation; or

Where you have given your consent (which can be withdrawn at any time).

We use information that we collect about you or that you provide to us for the following purposes:

To provide you the KOBN Services and the content and the other products and services that you request from us.

To provide the Site and its contents to you.

To confirm your identity in connection with the use of the KOBN Services.

To update the database that is managed and controlled by us.

To process and complete transactions and send you related information, including the request for and the provision of the KOBN Services.

To locate events and KOBN chapters near you.

To provide technical and other support to you.

To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, and events; and providing other news or information about us, our members and our select partners, provided you have given your consent if required by applicable law.

To enable Service Providers to perform certain responsibilities and provide certain services in connection with our business and operations.

To fulfill any other purpose for which you provide it.

To provide you with notices about your account.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To notify you about changes to the Site and the other KOBN Services.

To allow you to participate in interactive features on or through any of the KOBN Services.

To enhance the safety and security of all of the KOBN Services.

To verify your identity and prevent fraud or other unauthorized or illegal activity.

To enable marketing, remarketing and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and online behavioral advertising regarding our own and third-party products and services that we believe may be of interest to you, including advertisement on third party websites, provided you have given your consent if required by applicable law.

To contact you about promotional offers, marketing programs, or communications from KOBN, and the Service Providers with which KOBN has a partnership to provide certain services and products for our members, including affinity credit cards and other insurance, travel and financial products and services, provided you have given your consent if required by applicable law.

To perform targeted and other advertising on third party websites.

In any other way, we may describe when you provide the information.

For any other purpose with your consent.

Some of the information that we collect automatically is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Site and the other KOBN Services, and to deliver better and more personalized service, including enabling us to:

Estimate our audience size and better understand usage patterns.

Store information about your preferences, enabling us to customize the Site according to your individual interests.

Speed up your searches.

Recognize you when you return to the Site.

Storage and Transfer of Your Information

We may store any information that we collect (personal or otherwise) ourselves or in databases owned and maintained by us, our chapters and affiliates, agents or Service Providers.

If you access or use the Site or any of the other KOBN Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by KOBN and you. By allowing KOBN to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.

Although users from all over the world may access and use the Site and the other KOBN Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.

Disclosure of Your Information

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

We may disclose personal data that we collect or you provide as described in this privacy policy:

To our chapters and affiliates.

To other users in your organization in connection with any of the KOBN Services.

To Service Providers, we use to support our business as more particularly described in the Third-party Responsibilities and Services provision above.

To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of KOBN’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by KOBN about members and users of the Site is among the assets that may be or are actually transferred.

To fulfill the purpose for which you provide it.

For any other purpose disclosed by us when you provide the information.

With your consent.

We may also disclose your personal data:

To comply with any court order, law or legal process, including to respond to any government or regulatory request.

To enforce or apply the Terms and other agreements, including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of KOBN, our members or others.

We may share information that is anonymized or in an aggregated form that does not directly identify you and we may use and share any such information for any purpose without restriction so long as it does not violate the terms of this privacy policy or any applicable law. We will never sell that information but we may share it with our chapters and affiliates.

Choices About How We Use and Disclose Your Personal Data

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

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Site or the other KOBN Services may then be inaccessible or not function properly.

Promotional Offers from KOBN. If you do not wish to have your e-mail address/contact information used by KOBN to promote our own or third parties’ products or services, you can opt-out through your profile page or by emailing us at admin@kemperoldboy.com subject to the terms of the GDPR, this opt-out does not apply to information provided to KOBN as a result of a service or product purchase, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.

Accessing and Correcting Your Personal Data

You may change, correct or delete any personal data that you have provided to us through your subscriber profile page or by emailing us at admin@kemperoldboy.com. We may not accommodate a request to change personal data or other information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from any of the KOBN Services (including any User Content stored in the cloud), copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other users of the Servers or the Site. Proper access and use of information provided on or through any of the KOBN Services, including User Content, are governed by the Terms.

Your California Privacy Rights

California Civil Code Section §1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to admin@kemperoldboy.com or write to us at:

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European Privacy Rights for EEA Residents.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right by contacting us directly.

In certain circumstances, you have the right to: (a) request access to any personal data we hold about you and related data, (b) obtain without undue delay the rectification of any inaccurate personal data, (c) request that your personal data be deleted provided that the personal data is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim, (d) prevent or restrict processing of your personal data, except to the extent processing is required (i) to comply with a legal obligation under European or Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims; and (e) request transfer of your personal data directly to a third party where this is technically feasible.

If you are an EEA Resident in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.

If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us at admin@kemperoldboy.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

In addition, where you believe that we have not complied with its obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting us at admin@kemperoldboy.com or write to us at:

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How Long We Store Your Personal Data

We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfill the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. After that, we will either securely delete or anonymize your personal data so that it cannot be linked back to you.

Data Security

We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls to protect your personal data. However, despite our efforts, no security controls are 100% effective and KOBN cannot ensure or warrant the security of your personal data. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

The safety and security of your data also depend on you. Where we have given you (or where you have chosen) a password for access to and use of certain parts of the Site and/or the other KOBN Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of any of the KOBN Services. The information you share in public areas may be viewed by any user of the Site.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the home pages of the Site for at least 30 days. If we make material changes to how we treat our users’ personal data that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home pages of the Site and to attempt to get your consent to the changes. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Site and this privacy policy to check for any changes. Like our Terms, of which this privacy policy is a part, your use, and/or continued use after our efforts to contact you, of the Site or any of the other KOBN Services, means that you agree to be bound by such changes.

Survival

The policies indicated in this privacy policy will remain effective, even if the Terms and the other agreements between us are terminated and you are no longer a member of KOBN, using the Site or any of the other KOBN Services.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices or need to reach us for any other reason, you may contact us by e-mail at admin@kemperoldboy.com or by mail at:

Kemper Old Boy Network
10931 Keithstone Fairway Dr
Houston, TX 77095

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