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SOUTHERN CALIFORNIA ASSOCIATION of GOVERNMENTS

PRIVACY POLICY FOR COLLECTION, MANAGEMENT AND STORAGE OF PERSONAL INFORMATION
Southern California Association of Governments
KEY POINTS OF PRIVACY POLICY FOR COLLECTION, MANAGEMENT AND STORAGE OF PERSONAL INFORMATION (“PRIVACY POLICY”):
·         SCAG collects data from your use of SCAG online services and programs.
·         If you use SCAG online services and programs, SCAG may use your Personally Identifiable Information to better administer these programs and services.
·         SCAG safeguards your Personally Identifiable Information and uses it only for legitimate purposes.
·         Your use of SCAG’s websites, programs and services constitutes agreement and acceptance of the terms and conditions of this Privacy Policy and the SCAG Website Terms of Use.
OVERVIEW OF THIS PRIVACY POLICY
This Privacy Policy describes the information we collect from you as part of your use of this site and related services and how that information will be used. This policy is detailed because we believe you should know as much as possible about SCAG practices so that you can make informed decisions.

You accept this Privacy Policy and the SCAG Website Terms of Use through your use of SCAG’s websites and related services and in doing so you, consent to SCAG’s use and disclosure of your Personally Identifiable Information in accordance with this Privacy Policy. This Privacy Policy is effective as of March 2013.

If we update this Privacy Policy, we will post the updates on SCAG’s websites and send email notifications to users who have provided contact information via SCAG’s Registration system (available at the top right of most website pages).

By visiting the SCAG websites you agree to be bound by the terms and conditions of this Privacy Policy.

If you have additional questions, you may send an e-mail to SCAG by clicking on the link entitled “Contact Us” which is at the bottom of most website pages.

This Privacy Policy constitutes the entire agreement between you and SCAG with respect to the collection, use, storage and disclosure by SCAG of Personally Identifiable and Aggregate Information obtained from SCAG websites or from participation in any of SCAG’s programs or services. Your use of any of these programs and services constitutes your agreement to all such terms, conditions, provisions, and notices set forth in this policy.
 
 
Contents
 
I.  INTRODUCTION
 
II. DATA SCAG COLLECTS
 
III. USE OF YOUR INFORMATION
 
IV. SECURITY: HOW SCAG SAFEGUARDS INFORMATION COLLECTED
 
V. USE OF SCAG INTERNET SITES & SERVICES
 
VI. OTHER PROVISIONS
 
V11. DEFINITIONS
 
 
I. INTRODUCTION
The Southern California Association of Governments (SCAG) wants to assure you that it respects your privacy and the confidentiality of your Personally Identifiable Information. That is why SCAG collects only the information that is needed to serve you and administer SCAG’s programs.

SCAG follows the principles outlined below, which are in accordance with practices for customer privacy and data protection in the State of California.

This Privacy Policy governs SCAG’s information practices with respect to (i) information that site visitors directly or indirectly provide while using SCAG’s websites and (ii) information collected from users that choose to participate in SCAG services and programs.

Please read this Privacy Policy carefully; it constitutes the agreement between you and SCAG regarding SCAG’s collection and use of personal, financial and other information you may provide SCAG while using SCAG’s websites, or participating in SCAG programs or services.
 
II. DATA SCAG COLLECTS
Once you register on the SCAG websites, you are not anonymous to SCAG. For various services on the websites, SCAG may require you to provide appropriate information as indicated on the forms throughout the websites. SCAG only asks for, and compiles, Personally Identifiable Information that is needed to provide you with the product or service that you seek.
  • Some of SCAG’s programs require you to provide us with contact information and other Personally Identifiable Information to demonstrate eligibility for this service, and that you allow SCAG broader abilities to use that information in order for you to participate in these programs.
  • Where possible, SCAG indicates which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature. If you are uncomfortable with providing the requested level of information, or with SCAG’s use of this information for the particular purposes identified, you may simply decline to order that level of service or participate in that particular program.
  • If you choose not to provide SCAG with Personally Identifiable Information you may not be able to participate in certain SCAG programs and services. Please read on to learn more about this relationship between personalized services and your Personally Identifiable Information.
 
1. Automatically Collected Information
 

When you visit SCAG’s websites, some information may be automatically collected, such as:
 
  • The Internet domain and IP address from which you access SCAG’s websites;
 
  • The type of browser and operating system used to access SCAG’s websites;
 
  • “Clickstream Data”: The date and time you access SCAG’s websites; the pages you visit; and if you linked to SCAG’s websites from another website, the address of that website.
 
 
 
An Internet Protocol (IP) address is associated with your computer’s connection to the Internet. SCAG uses your computer’s IP address to maintain contact with you as you navigate through SCAG’s websites. Your computer’s IP address by itself does not identify you personally and thus this information (IP addresses) is considered as Aggregate Information.
Clickstream data is information concerning the sequence of mouse clicks made by a website user, or the pages viewed by users, or the amount of time users spend on a certain page, and other similar information. Clickstream data can be thought of as a “trail” that users make while navigating through a Web site. Clickstream data does not identify you personally.
SCAG uses the above automatically collected information to count the numbers and types of visitors to the different pages on SCAG’s websites to help SCAG make these websites more useful to visitors like you.
 
 
 
2. Cookies
 
Cookies are small text files that a website can use to recognize repeat users, to facilitate the users’ ongoing access to and use of the site, and to compile aggregate data to improve the site and related business purposes.
SCAG uses cookies for a variety of purposes, including, but not limited to the following:
  1. To assist SCAG in providing services to you;
  2. To allow you to change pages during your visit to SCAG’s websites without repeatedly having to re-enter your password (if you have registered on SCAG’s websites you will have a password); and
  3. To track activity on SCAG’s websites.
You can usually set parameters on your computer that allow you to elect to accept cookies or to have your browser notify you each time a cookie is offered. You can also usually delete cookies from your hard drive. You can find instructions on how to accept cookies, on how to be notified that a cookie is being offered, and on how to delete cookies through your browser. If you wish, you can generally set your Internet browser software to reject cookies by following the instructions for disabling cookies in the “Help” section of your browser.
If your browser does not accept cookies from SCAG’s websites or if you disable cookies on your browser, some features provided may not function properly.
Cookies, by themselves, do not collect or retain your name or other Personally Identifiable Information. SCAG does not use cookies to collect or retain your name or other Personally Identifiable Information without first informing you, as set out in this Policy. In addition, no third parties are permitted to use cookies SCAG may create via SCAG’s websites for their own purposes.
 
 
 
3. E-mail Addresses and Other Communications
 
In order for you to use certain SCAG services, you may have to register on SCAG’s websites.  To register on SCAG’s websites you will need to provide an email address and your name, which are required. We request additional optional information in order to serve you better, but you do not need to provide this information in order to register.
SCAG validates the email address you provide by sending a confirmation email to that address with a URL for you to follow to complete your registration process. There are many Web sites today which offer free or paid email accounts which you can subscribe to should you require an email address.
If you send SCAG an email or letter with questions or comments, or if you provide your contact information when requesting services from SCAG, SCAG may use your email address and other Personally Identifiable Information included in your correspondence in order to respond to you.
In order for SCAG to send you newsletters and other communications, you must grant SCAG permission to do so by subscribing to these services.  In order to subscribe to these services, you must register on SCAG websites.  The Register button is at the top right of most website screens.  If you have already registered, you will need to login in order to participate in these services.
 
 
 
4. Surveys
 
From time to time SCAG may conduct online surveys that site visitors may complete on a voluntary basis. These surveys are optional. The collection of information through surveys is done anonymously, unless personal identifiable information is requested and voluntarily submitted, and will only be used for the purpose of marketing or planning services.
 
III. USE OF YOUR INFORMATION
SCAG collects Personally Identifiable Information in order to deliver the information and services you request easily and efficiently and to administer SCAG services and programs.
Information you may provide while visiting SCAG’s websites or participating in SCAG’s programs fall into two broad categories:
  1. Personally Identifiable Information
  2. Aggregate Information:
  • Personally Identifiable Information means any information that could reasonably be used to identify you, including your name, street address, email address, telephone number and work contact information or any combination of such information that could be used to identify you.
  • Aggregate Information is information that does not personally identify you, and may include statistical information concerning use of SCAG website tools and services or the pages on SCAG’s websites that users visit most frequently. SCAG’s Privacy Policy governs both categories of information as detailed in this Privacy Policy.
Additionally, SCAG may use any information you provide to facilitate the services you request, troubleshoot problems, identify abuse of SCAG’s services, identify violation of SCAG’s terms of use, measure interest in SCAG’s services and enhance SCAG’s websites.
SCAG also gathers broad demographic information for aggregate use. SCAG may compare and review your Personally Identifiable Information for errors, omissions and for accuracy.
The privacy of your Personally Identifiable Information is a serious matter. Safeguarding and protection of Personally Identifiable Information is a high priority to SCAG. SCAG will not sell or distribute your Personally Identifiable Information outside of SCAG’s member agencies unless you expressly consent for us to do so.
You decide whether you wish to provide SCAG with Personally Identifiable Information. You have the option to use certain parts of SCAG’s services and elect not to “register” your Personally Identifiable Information in SCAG’s system.
Some services, however, will mandate the registration of your Personally Identifiable Information with such services. As such, you decide whether you wish to participate in website Services that rely on Personally Identifiable Information.
 
1. Third Parties
 
It is possible that certain SCAG services may be contracted to outside service providers. Personally Identifiable Information that SCAG collects will be disclosed only to SCAG employees, officials or service providers on a “need to know” basis for purposes of fulfilling their responsibilities to SCAG.  They will use the information to answer your questions, respond to any requests for assistance, and fulfill SCAG’s operational and legal obligations. If this occurs, the service provider would have access to the information maintained by SCAG, including customer account information, but will be contractually bound to protect your information in accordance with this Privacy Policy.

SCAG may also use website analytic data, including Personally Identifiable Information, for internal studies conducted by SCAG or SCAG’s agents or outside service providers in which you may be invited to participate. To the extent that an outside service provider is utilized in conducting such studies, they will be contractually bound to treat your information in full accord with this Privacy Policy.
Upon receipt of a communication, inquiry, or other request from you, where appropriate SCAG may provide the information submitted by you to the person or company that is the subject of your inquiry or to a government agency responsible for the matters referred to in your communication.
SCAG does not share Personally Identifiable Information that you provide to us with any Unrelated Third Parties except as specified herein or as may be required by law.
 
 
 
2. Forms and Monetary Transactions
 
If you choose to engage in certain activities on this site, such as registering on SCAG’s websites in order to receive newsletters or registering and (potentially) paying for attendance at an event, SCAG may ask you to provide Personally Identifiable Information by filling out and submitting an online form. These activities are completely optional for you to engage in, however.
Under such circumstances SCAG may ask that you provide information such as your first and last name, home or business mailing address (including ZIP code), e-mail address, employer name, job title and department, telephone and facsimile numbers that may be used for verification.
Some of the information that SCAG asks you to provide is identified as mandatory and some as voluntary. If you choose not to provide the mandatory information with respect to a particular activity, you will not be able to engage in that activity.
 
 
 
3. Creating an Online Account
 
In order to use certain services offered by SCAG via the Internet you may need to register and provide SCAG with Personally Identifiable Information including contact information. However, if you do not wish to provide SCAG with this Personally Identifiable Information, you will not be able to utilize such online services.
 
 
 
 
 
4. Updating or Removing Your Information
 
To allow you appropriate control over your Personally Identifiable Information, you can request access to review, change, update, or delete Personally Identifiable Information that you have previously submitted. We will take reasonable steps to verify your identity before granting access to your Personally Identifiable Information.
 
 
 
5. Disclosure of Personally Identifiable Information in Conjunction with Legal Proceedings
 
SCAG may release Personally Identifiable Information collected in relation to your use of SCAG’s website services in response to a verified request or search warrant by law enforcement, immigration, customs or other government officials relating to a criminal investigation or alleged illegal activity, SCAG can (and you authorize SCAG to) disclose your name, street address, city, state, postal code, country, telephone number(s), email address and additional information SCAG maintains about you, with a subpoena or comparable legal process.
In any case, SCAG will seek to limit the scope of the disclosure and restrict such disclosures only to appropriate authorities, and will disclose only such Personally Identifiable Information as is reasonably required to fulfill the purpose of the disclosure.
Persons who receive information in proper accordance with the procedures set out in this Section (“Proper Recipients”) may be able to combine information they properly obtain from us under this Section with other information they independently possess concerning you. As long as SCAG complies with the procedures set out in this Section concerning the release of information, SCAG will not be responsible for Proper Recipients’ later use of this information.
In addition, SCAG reserves the right at all times to disclose any information it deems reasonably necessary to satisfy any applicable law, regulation, legal process or governmental request, or to edit, refuse to post or to remove any information or materials, in whole or in part, at SCAG’s sole discretion.
 
 
IV. SECURITY: HOW SCAG SAFEGUARDS INFORMATION COLLECTED
SCAG has put into place security systems designed to prevent unauthorized disclosure of information you provide to SCAG and to deter and prevent hackers and others from accessing this information. For example, SCAG has taken steps to safeguard the integrity of SCAG’s telecommunications and computing infrastructure, including but not limited to authentication, monitoring, auditing, and encryption.

SCAG uses standard security measures to minimize the threat that your Personally Identifiable Information will be lost, misused, altered, or unintentionally destroyed. SCAG also uses software programs to monitor network traffic to attempt to identify unauthorized attempts to upload or change information, or otherwise cause damage.

These safeguards should not be construed in any way, however, as giving business, legal, or other advice, or warranting as fail-proof, the security of information provided by or submitted to SCAG websites and of information submitted through participation in SCAG services, programs, or SCAG’s website services. Because SCAG websites do not encrypt incoming e-mail, you should not send e-mail containing information that you consider highly sensitive through this website.

If SCAG detects, despite the safeguards set out in this section, an intrusion or other unauthorized access to or use of Personally Identifiable Information (an “Intrusion”), SCAG will notify affected registered site visitors of the Intrusion, and will (i) deliver this notice by the means SCAG deems most efficient under the circumstances (such as, for example, first class mail or e-mail), or by other means as required by applicable law; (ii) use contact information for each affected site visitor that is current in SCAG’s files; and (iii) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner.

Due to the nature of Internet communications and evolving technologies, SCAG cannot provide and disclaims assurance that the information you provide to SCAG will remain free from loss, misuse, or alteration by third parties, who, despite SCAG’s efforts, obtain unauthorized access.

SCAG shall have no liability in tort, contract, or otherwise if unauthorized third parties unlawfully intercept or access transmissions or private communications to trace your Personally Identifiable Information, or an external user illegally acquires your Personally Identifiable Information from SCAG’s websites.
 
V. USE OF SCAG INTERNET SITES & SERVICES
 
1. Privileges
 
By accepting the provisions of this Privacy Policy and SCAG Website Terms of Use, you agree, as a user of SCAG websites, services, and programs, that:
  • You will refrain from activity that imposes an unreasonable burden on the site, and SCAG reserves the right, at SCAG’s discretion, to refuse service to any customer who violates these provisions;
  • You will not use your access to any SCAG website or any program or service organized directly or indirectly through the website, for any purpose that is unlawful or prohibited by these terms of use;
  • You will not use any SCAG website or any program or service to:
    • Defame, abuse, harass, stalk or threaten others;
    • Collect information about others, including e-mail addresses, without their consent;
    • Create a false identity;
    • Transmit or upload any material that contains harmful or deleterious computer programs (including, without limitation, viruses, trojan horses, worms, time bombs or cancelbots);
    • Transmit or upload any computer programs or other material in breach of any intellectual property laws, rights of privacy or any other applicable laws;
    • Interfere with or disrupt networks connected to the website or violate the regulations, policies or procedures of such networks;
    • Attempt to gain unauthorized access to the website, other accounts, computer systems or networks connected to the website, through password mining or any other means; and
    • Interfere with another user’s and enjoyment of the website.
You will comply with all relevant laws and regulations and are solely responsible for all acts or omissions that occur under your, or through the use of, your password.
  • You allow SCAG to use your Personally Identifiable Information internally to improve SCAG’s content and services.
  • You allow SCAG to use your Personally Identifiable Information to contact you and deliver notifications to you related to the specific programs in which you have voluntarily enrolled or subscribed, including updates to this policy.
  • SCAG may communicate with you about products and services offered by itself, its partners or agents using your name, street address, and electronic mail address, but only if SCAG has received your express written consent to receive such communications.
  • SCAG reserves the right to send notifications of any changes to or new features of SCAG’s websites. By accepting the User Agreement and Privacy Policy, you agree to receive these notifications.
 
 
 
2. Account Changes
 
If you registered for an online account on a SCAG site, you can review the Personally Identifiable Information that you provided to SCAG and make desired changes to allowed fields of this information, or to the settings for your account, at any time by logging in to your account on the website and choosing the “Login” option at the top of most website pages. For certain services, you may not be allowed to change certain information you entered at the time of registration.
If you close your account, your Personally Identifiable Information will continue to be governed and protected by these policies. Your Personally Identifiable Information may be held in SCAG databases for up to four years and six months after your account is closed or terminated.
We strongly recommend that you not disclose your website password to anyone and to use a unique password for your SCAG login account, a password that you do not use for other accounts.  If your password has been compromised for any reason, you should immediately change your password through SCAG’s website.
 
 
 
3. Personal & Non-Commercial Use Limitation
 
Unless otherwise specified, SCAG websites and services are for your personal and non-commercial use. You may not modify, publish, license, create derivative works from, transfer, or sell any information, software, products, or services obtained from the SCAG websites, without the advance express written permission of SCAG.
 
 
 
4. Termination / Access Restriction
 
SCAG reserves the right, in its sole discretion, to terminate your access to any or all its websites and the related services for any portion thereof at any time, without notice. SCAG may also terminate or suspend your access to the SCAG websites for inactivity, which is defined as failing to log into a particular service for an extended period of time, as determined by SCAG, or to re-subscribe to a service within one year.
 
 
 
5. Privacy Protection for Children
 
SCAG websites are not directed at children, and we will not accept or request Personally Identifiable Information from individuals we know to be under 13 years of age. In accordance with the Children’s Online Privacy Protection Act of 1998, if we learn that a child under 13 years of age has provided us with Personally Identifiable Information, we will delete this information from SCAG’s databases.
SCAG wants to assist you in guarding your children’s privacy. SCAG encourages you to discuss safe and responsible use of Personally Identifiable Information while using the Internet.
You can find more information on this subject at http://www. americalinksup.org, and under the Children’s Online Privacy Protection Act, available at http://www.ftc.gov/ogc/coppa1.htm.
 
 
VI. OTHER PROVISIONS
 
1. California Public Records Act Requests
 
Certain information held by SCAG may be subject to state public records laws. Dissemination of such information is governed by applicable California statutory provisions. Any dissemination of such information will be conducted in conformance with such laws.
SCAG reserves the right to impose reasonable charges for responding to records  requests under the California Public Records Act. Fees for copies of records which are disclosed shall be assessed in accordance with state laws and SCAG’s Public Records Request Guidelines.
 
 
 
2. Links
 
SCAG’s websites may contain links to other sites (“Linked Sites”). The Linked Sites are not under the control of SCAG and SCAG is not responsible for the content of any Linked Site, including without limitation any link contained in a Linked Site, or any changes or updates to a Linked Site. In addition, SCAG is not responsible for the privacy practices of other sites. SCAG is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by SCAG of the site or any association with its operators. You are responsible for viewing and abiding by the privacy statements and terms of use posted at the Linked Sites. We encourage website visitors to be aware when they leave SCAG’s websites and to read the privacy policies of each website that collects Personally Identifiable Information. This Privacy Policy applies solely to information collected by SCAG’s websites.
While SCAG strongly encourages the creation of outside links to SCAG’s websites for the purpose of benefiting the public, SCAG’s members and partner agencies, SCAG must reserve the right to request that site visitors do not frame any part of SCAG’s website material by including advertising or other revenue generating material. The user hereby agrees to remove or cease any link upon SCAG’s request. Users may not frame any part of the SCAG website material by including advertising or other revenue generating material.
 
 
 
3. Third Parties, Sponsors and Vendors
 
Any dealings with any third parties, sponsors or vendors appearing on the website are solely between you and the third party, sponsor or vendor.  SCAG is not responsible or liable for any part of any such dealings.
 
 
 
4. Changes to this Privacy Policy
 
SCAG reserves the right to change the terms, conditions, and notices under which the SCAG websites and services are offered. You are responsible for regularly reviewing these terms and conditions and any additional terms posted.
If SCAG decides to change this Privacy Policy,  changes will be posted here so that you will always know what information SCAG gathers, how it might be used, and whether SCAG will disclose it to anyone. Your use of this site will be subject to the most current version of the Privacy Policy at the time of such use.
SCAG will endeavor to post changes to this Policy at least ten days before they take effect.  SCAG will also notify users who hold online accounts with SCAG services of such changes. Any information SCAG collects under the current Privacy Policy will remain subject to the terms of this Policy. After any changes take effect, all new information SCAG collects, if any, will be subject to the new Policy.
 
 
 
5. Retention Period
 
SCAG retains records from SCAG services and programs on both SCAG’s active database systems and archive systems. These records contain Personally Identifiable Information and Aggregate Information.
 
 
 
6. Contact Us
 
SCAG welcomes your feedback, questions, concerns, or suggestions regarding SCAG’s Privacy Policy. You may contact SCAG through the following ways:
 
 
TELEPHONE
SCAG Main Office - Call (213) 236-1800
EMAIL
SCAG: ………………………… webmaster@scag.ca.gov
MAIL
Southern California Association of Governments
818 W 7th Street, 12th Floor
Los Angeles, CA 90017
 
 
 
7. Disclaimer Notice
 
SCAG makes no claims, promises or guarantees about the accuracy, currency, completeness, or adequacy of the contents of the SCAG websites and expressly disclaims liability for errors and omissions in its contents. In the event of a conflict between this Privacy Policy and the Public Records Act or other law governing the maintenance or disclosure of records, the Public Records Act or other applicable law will control. No warranty of any kind, implied, express or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to this Website or its links to other Internet resources. Although we have put in place security systems (as described in this Policy) that are designed to prevent unauthorized disclosure of your Personally Identifiable Information (PII), due to the nature of Internet technologies SCAG cannot provide firm assurances as to the security of this information, and expressly disclaim any such obligation.
 
 
 
8. Indemnification
 
You agree to indemnify and hold SCAG, its officials, officers, employees, sponsors, partners and agents harmless from any claims, actions, costs (including legal costs), or losses by any third party due to or arising out of your use of or conduct in relation to SCAG’s websites, including without limitation a breach of this Privacy Policy and SCAG Website Terms of Use.
 
 
 
9. Severability
 
The SCAG websites are controlled and operated by SCAG from its main location in Los Angeles, California. This Policy shall be construed in accordance with the laws of the State of California, without regard to any conflict of law provisions. Any dispute arising under this Policy shall be resolved exclusively by the state or federal courts sitting in Los Angeles, California. If any portion of these Terms of Use are deemed to be invalid, illegal or unenforceable the remaining provisions shall remain in full force and effect.
 
V11. DEFINITIONS
Aggregate Information is information that does not identify you, and may include statistical information concerning use of SCAG programs and services, or the pages on SCAG’s website that users visit most frequently.
SCAG uses Aggregate Information to analyze and improve the effectiveness of SCAG’s websites, services and programs. From time to time, SCAG may undertake or commission statistical and other summary analyses of the general behavior and characteristics of customers participating in any of SCAG’s and programs and the characteristics of visitors to SCAG sites, and may share Aggregate Information with third parties.
Aggregate Information provided to third parties will not allow anyone to identify you, or determine anything personal about you.
Data Subject means the individual identified by the Personally Identifiable Information at issue.
Personally Identifiable Information means any information that could reasonably be used to identify you, including your name, address, email address, birth date, financial information, photograph, telephone number or any combination of other information that could be used to identify you.
Unrelated Third Parties means anyone who is not involved in providing SCAG services, running a SCAG affiliated Website, or fulfilling requests you make concerning such Websites or SCAG systems.
You and Your refer to any person (i) who accesses this site, or (ii) whose Personally Identifiable Information is provided to SCAG.
“We,” “Us,” and “Our” mean SCAG and its agents and contractors.
Website Services means the information, purchases, and Managed Account services that we offer through SCAG’s website.
Revised: March 1 2013
 
 
Copyright © 2014 Southern California Association of Governments. All Rights Reserved.