Privacy Policy

You may provide us Personal Information when you:

• request information;
• request services;
• register for an event;
• submit a membership application;
• subscribe to our emails;
• purchase from the LCI Shop; or
• register yourself with the Website.

The information that you provide in each case will vary. In some cases, we may ask you to create a username and password that should only be known to you.

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to the Websites.  We collect this information using automated tools that are detailed below.  These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Websites.  Some of the tools we use to automatically collect information about you may include:

(a) Cookies. A “cookie” is a small data file transmitted from a website to your computer’s hard drive.  Cookies are usually defined in one of two ways, and we may use both of them:

(1) session cookies, which do not stay on your computer after you close your browser, and

(2) persistent cookies, which remain on your computer until you delete them or they expire.

We use the following categories of cookies on our Websites.

i. Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Websites and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items (e.g. a shopping cart), cannot be provided.

ii. Performance Cookies. These cookies collect anonymous information on how people use our Websites to help us understand how you arrive at our site, browse or use our Websites and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.

iii. Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Websites, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Websites more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.

iv. Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks.  These cookies remember the websites you visit and that information is shared with other trusted third parties.

One such trusted third party partner is Google Analytics.  The Websites send aggregated, non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Websites’ performance.  For more information on how Google Analytics supports the Websites and uses information sent from the Websites, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Websites’ features or lose access to some functionality.

(b) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our third party marketing partners may use Web Beacons to track your interaction with online advertising banners on the Websites.  This information is only collected in aggregate form and will not be linked to your Personal Information.  Please note that any image file on a webpage can act as a Web Beacon.

(c) Embedded Web Links. Links provided in our emails and, in some cases, on third party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients.  Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

(d) Third Party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on the Websites and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third party websites.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed to the service.  Any transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information.  After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

Information of Minors

We do not actively seek to gather information from individuals under the age of eighteen.  We do not target the Websites to minors, and would not expect them to be engaging with the Websites or services.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• • • providing the information, products and services you request;
    • security, credit or fraud prevention purposes;
    • providing you with effective customer service;
    • providing you with a personalized experience when you use this Website;
    • contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
    • contacting you with information and notices related to your use of this Website;
    • inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
    • better understanding your needs and interests;
    • improving the content, functionality and usability of this Website;
    • improving our products and services;
    • improving our marketing and promotional efforts; and
  • • any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

How We Disclose Your Information

We do not sell or lease your information to any third party.  We may disclose your Personal Information to our affiliates and our trusted third party business partners in accordance with this Policy. We work with a number of partners that help us process your requests, register you for events, conduct webinars, deliver customer service and support, send email marketing communications, and provide experiences that you have come to expect from us.  We will share your information with these third parties in order to fulfill the service that they provide to us.  These third party partners are under contract to keep your information secure and not to use it for any reason other than to fulfill the service we have requested from them.  For example, when you provide us with your credit card number to fulfill an order, we share your number with a trusted third party that is responsible for processing and securing your credit card information.

Additionally, we may publicly identify, both through the Website and in print, the names and logos of our members that use LCI services, including eLearning participation.  If you do not want your  name and logo to be shared in this way, please contact us at privacy@leanconstruction.org.

In the preceding twelve (12) months, we may have disclosed the following categories of Personal Information for one or more business purposes:

• • • Identifiers;
    • Commercial Information;
    • Internet or other network activity information; and
    • Inferences drawn from other Personal Information.

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• • • Responding to duly authorized information requests from law enforcement or other governmental authorities.
    • Complying with any law, regulations, subpoena, or court order.
    • Investigating and helping prevent security threats, fraud, or other malicious activity.
    • Enforcing or protecting the rights and properties of LCI or its subsidiaries.
    • Protecting the rights or personal safety of LCI’s employees.

Sale of Business or Merger. There are circumstances where LCI may decide to buy, sell, or reorganize its business in selected countries.  Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, LCI will ensure your information is used in accordance with this Policy.

Third Party Websites
This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates.  The Websites may link to third party websites and services, but these links are not endorsements of these sites, and this Policy does not extend to them.  Because this Policy is not enforced on these third party websites, we encourage you to read any posted privacy policy of the third party website before using the service or site and providing any information

For Website Visitors Outside of the United States

Many visitors to the Websites may be located outside of the United States.  To provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

Your Rights Under State Law

California

• • • Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
    • Do Not Track Signals. Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising.  Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.
    • WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.

Your Consumer Rights

Some state laws in the United States provide consumers with additional rights with respect to their personal information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 (the “CCPA”) as amended by the California Privacy Rights Act, the Colorado Privacy Act (“CPA”) and the Virginia Consumer Data Protection Act (“VCDPA”).  Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your personal information, you may exercise each of your rights as identified below, subject to our verification of your identity.

A. Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

B. Correction. You can correct what personal data our Website database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.

C. Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

D. Portability. Upon request and when possible, we can provide you with copies of your Personal Information.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy

E. Deletion. You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.  Where applicable, we will ensure such changes are shared with trusted third parties.

F. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.

G. Non-Discrimination. If a data subject exercises his or her rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.

H. Exercising your rights. If you are a data subject that has rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, who chooses to exercise the rights listed above, you can:

• • 1. Submit a request via email at privacy@leanconstruction.org; or
    2. Call us at [PHONE NUMBER] to submit your request.

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.  If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

For Website Visitors in the European Union (“EU”)

Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR.  For the purposes of this Policy, LCI operates as a data controller.  Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing.  You may always withdraw your consent to our use of your personal data as described below.  We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

You can exercise any of the following rights by notifying us as described below:

• • • Access. You may email us at privacy@leanconstruction.org to request a copy of the personal data our Website databases currently contain.
    • Correction or Rectification. You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us at privacy@leanconstruction.org to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
    • Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to privacy@leanconstruction.org. In your email, please explain how you wish us to restrict processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
    • Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to privacy@leanconstruction.org. When such objections are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.
    • Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to privacy@leanconstruction.org.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent.  Where applicable, we will ensure such changes are shared with any trusted third parties.
    • Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through the Websites by notifying us via email at privacy@leanconstruction.org. Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email.  Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data.  Where applicable, we will ensure such changes are shared with trusted third parties.
    • Erasure. If you should wish to cease use of the Websites and have your personal data deleted from our Website, then you may submit a request by emailing us at privacy@leanconstruction.org. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted.  Where applicable, we will ensure such changes are shared with trusted third parties.
    • Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

Safeguarding the Information We Collect

We take reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise 100% security.  You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password.  If you believe your credentials have been compromised, please change your password. Please also notify us of any unauthorized use.

Changes to this Policy

If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of the Websites by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

How to Contact Us

We value your opinions and welcome your feedback.  To contact us about this Policy or your Personal Information, please contact us at

Ilene Goldberg
ATTN: Privacy
1400 North 14^th Street, 12^th Floor
Arlington, VA 22209
privacy@leanconstruction.org

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