Ice Nine Online is committed to maintaining robust privacy protections for its users.  Our Privacy Policy is designed to help you understand how we collect, use, and protect the information you provide to us and to assist you in making informed decisions when using our website.

Ice Nine Online reserves the right to modify this Privacy Policy at any time.  Please visit this page periodically to inform yourself of any changes to our Privacy Policy.  Your continued use of this site indicates your awareness of and agreement to the terms and conditions stated herein.  Any questions or comments about this privacy policy are welcome and can sent to messages@icenineonline.com.

What information do we collect?

We collect “Non-Personal Information” and “Personally Identifiable Information/PII.”  Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit, and preferences that are generated based on the data you submit and number of clicks.  Personally Identifiable Information/PII is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context, such as your name, email address, mailing address, or phone number.

When do we collect information?

We collect information from you when you register for an event, subscribe to a newsletter, respond to a survey, apply for a job through our online career center, receive our publications, fill out a form, submit a supplier registration or update form, or enter information on our site or in person.

How do we use your information?

We may use the information we collect from you when you register on our site, subscribe to a publication, register for an event, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

• To personalize user experience and to allow us to deliver the type of content and service offerings in which you are most interested.
• To improve our website to better serve you.
• To allow us to better serve you in responding to your customer service requests.
• To send marketing emails promoting and informing you of other products and services and invite you to events.

For job applicants, we collect and use information you provide us when submitting online applications for job vacancies or otherwise when you express your interest to join our team.  If you are selected for an opening, your personal data shall be further processed and kept confidential in accordance with our employee policies at the point of your onboarding.

How do we protect your information?

We implement a variety of security measures designed to protect your information from unauthorized use.  We use technological security measures including encryption, firewalls, continuous vulnerability and malware scanning, and secure socket layer technology.  Your information is contained behind secured networks and is only accessible by a limited number of people with special access rights who are required to keep the information confidential.  However, these measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of such firewalls or secure servers.  By using our website, you acknowledge that you understand and agree to assume these risks.

Do we sell or transfer your information?

We do not sell, trade, rent, share, or otherwise transfer your PII to outside parties without your consent.  This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.  We may also release your information when we believe in good faith that such disclosure is reasonably necessary to comply with the law, enforce our site policies, address fraud, or protect against harm to the rights, property, or safety of our company, our users, or the public as required or permitted by law.

This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information, and we reserve the right to use and disclose such Non-Personal Information to other parties for marketing, advertising, or other uses.

What are your rights regarding the use of your information?

You have the right at any time to prevent us from contacting you for marketing purposes.  When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each email.

Do we use “cookies”?

Yes.  Cookies are small files that a site or its service provider transfers to your computer/device’s hard drive through your web browser (if you allow) that enable the site’s or service provider’s systems to recognize your browser and capture and remember certain information.  They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services.  We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Understand and save user’s preferences for future visits.
• Keep track of advertisements and marketing activities.
• Compile aggregate data about site traffic and site interactions to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer/device warn you each time a cookie is being sent, or you can choose to turn off all cookies.  You do this through your browser settings.  If you disable cookies in your browser, some features of our website will be disabled, including the features that make your site experience more efficient, and some of our services will not function properly.  Your personalized preferences and experiences will also be null.

How do we use third-party links?

We do not include or offer third-party products or services on our website.  The website may contain hyperlinks to non-Ice Nine Online websites that may be of interest to users.  Ice Nine Online does not control or monitor the privacy, accuracy, quality, or integrity of those sites.  You should check the privacy notice and policies of each website you visit.  Links to third-party sites are provided solely for your convenience, and any use or submission of data to such sites shall be at your sole risk.

Do we use Google AdSense?

No.  We have not enabled Google AdSense on our site.

How do we comply with the California Online Privacy Protection Act (CalOPPA)?

In order to comply with CalOPPA, we agree to the following:

• Users can visit our site anonymously.
• Once this privacy policy is created, we will add a link to it on our home page or, as a minimum, on the first significant page after entering our website.
• Our privacy policy link includes the word privacy and can be easily be found on the page specified above.
• Users will be notified of any privacy policy changes on our privacy policy page.
• Users are able to change their personal information by submitting a form with new information.

How do we comply with the Children Online Privacy Protection Act (COPPA)?

This website and Ice Nine Online’s services are not directed to anyone under the age of 13.  We do not knowingly collect or solicit information from children under 13, or allow anyone under the age of 13 to sign up for any programs or services through our website.  In the event that we learn that we have gathered PII from a person under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible.  If you believe we have collected such information, please contact us at messages@icenineonline.com.

How do we comply with the CAN-SPAM Act?

We may collect your email address in order to send information, respond to inquiries and/or other requests or questions, market to our mailing list or continue to send emails to our clients, and invite our clients to events.  In order to comply with the CAN-SPAM Act, we agree to the following:

• We will not use false or misleading subjects or email addresses.
• We will identify appropriate emails as an advertisement in some reasonable way.
• We will include the physical address of our business or site headquarters in marketing emails.
• We will monitor third-party email marketing services for compliance, if one is used.
• We honor opt-out/unsubscribe requests.
• We allow users to unsubscribe to marketing emails by using a link in each email.

Legal Basis for Processing Personal Information (EEA Visitors Only)

If you are a visitor/customer located in the European Economic Area (EEA), Ice Nine Online is the data controller of your PII.  Ice Nine Online can be contacted at messages@icenineonline.com.  Our legal basis for collecting and using PII as described above will depend on the PII concerned and the specific context in which we collect it.  However, we will generally only collect PII from you when we have your consent to do so, when we need PII to perform a contract with you, or when the processing is in our 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 PII from you.  If we ask you to provide PII 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 PII is mandatory or not as well as of the possible consequences of not providing such information.  Similarly, if we collect and use your PII in reliance on our legitimate interests (or those of any third-party), we will make clear to you at the relevant time what those legitimate interests are.