Introduction
This Privacy Policy sets forth the data protection policies and practices of the NEXSO Web Site (the “Site”), an interactive online forum established and supported by the Multilateral Investment Fund (“MIF”), a fund administered by the Inter-American Development Bank (“IDB”) (collectively referred herein to as “IDB-MIF”, “we” or “us”). As explained in the NEXSO Terms of Use [hyperlink], into which this Privacy Policy is incorporated by reference, the IDB is an international organization established by its member countries pursuant to the Agreement Establishing the Inter-American Development Bank, and the MIF is a trust fund established by the IDB member countries through the Agreement Establishing the Multilateral Investment Fund II, and the Agreement for the Administration of the Multilateral Investment Fund II. For more information on the MIF, the IDB, and the NEXSO Site and its operations, please review carefully the NEXSO Terms of Use.
By using the Site, either as a visitor or a registered user (“User”), you are agreeing to the terms of this Privacy Policy, including as they may be amended from time to time. Your use of the Site therefore constitutes your consent to our collection, use and disclosure of personal information we collect from you through the Site, as described herein. Please be sure to read this entire Privacy Policy before using the Site.
As the Website is updated and expanded, our Privacy Policy may change, so please review the posted Privacy Policy from time to time. We will notify you about material changes in the way we treat personal information by placing a notice on the Website or by sending you an e-mail (if you have provided us your e-mail address).
Scope and Definitions
This Privacy Policy sets forth our policies and practices with respect to information concerning visitors to the Site, including how we collect, use, share and store that information. Although this Policy applies only to information collected through the Site, it is consistent with our policies and practices with respect to all personal information received by the IDB-MIF, whether in electronic, paper or verbal format.
As used in this Policy, the following terms have a specific meaning:
- Personally Identifiable Information
- PII is information that is about or pertains to a specific individual and can be linked to (identified with) that individual.
- Anonymous Information
- Aggregated information, demographic information and any other information that does not reveal the specific identity of an individual.
- An IP Address
- The Internet Protocol address of the computer an individual uses to access the Site (and the Internet more generally).
Collection of Information through the Site
Information You Submit
If you register as a NEXSO User, we will collect certain PII from you, including your institution, full name, postal address, e-mail address, phone number, and social network (e.g., LinkedIn, Facebook) information. All of this PII data will be available both to all registered Site users and to any non-registered visitors who may view or browse the Site. We are not responsible for the use or disclosure of such PII by other Site users and visitors. In providing us with such PII, you therefore assume the risk associated with any use or disclosure of such PII by other Site users and visitors.
In addition, even if you do not register as a NEXSO User, we will collect PII you provide to us in other ways, such as if you send us an e-mail via the “Contact Us” page of the Site, or post information in shared areas of the Site. [[NOTE: include a warning note on information screen so that when users are filling in their PII, they know this will all be publicly available on the Site—with a link to the privacy policy.]]
Information Automatically Collected
When you visit the Site, certain Anonymous Information is automatically collected relating to that visit. TheIDB-MIF’s web servers collect anonymous logs during user visits to the Site. This may be done through cookies, “clear GIFs” (a/k/a “web beacons,” or “pixel tags”), or similar technologies to retain information about you and your use of the Site.
Cookies are small data files that are sent to your browser or related software from a web server and stored on your computer or device. Cookies often include an anonymous unique identifier and track and store your user preferences while using the Website as well as technical information about your use of the Website.
Most web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, the Site or certain areas or features of the Site. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/.
We automatically collect data about your IP Address. Also, if you access the Site from a mobile or other device, your unique device identifier assigned to that device or other transactional information for that device may also be collected.
All of these technologies are designed to improve and personalize your experience using the Site. By using the Site, you consent to the use of the tracking technologies as described above.
Use of Information Collected Through the Site
We may use the PII we collect from you (as described above) to send you e-mail messages, mailings, or otherwise contact you in response to your requests. We also may use your PII to send you information that might interest you, such as descriptions of new projects, MIF and IDB activities, funding resources, etc. In addition, we may use your PII for recordkeeping purposes within the IDB-MIF, and we may combine the PII we collect from you with other information, including both PII and non-PII obtained from other sources, including other Users, for purposes of analysis relevant to the Site and theIDB-MIF’s objectives.
Where you have requested to receive e-mail updates from us, we may periodically send you emails that promote or otherwise contain information relating to the use of the Site and/or the MIF and/or the IDB. When you receive an e-mail from us, you may indicate a preference to “opt out” of, and thus to stop receiving further e-mails from us, by following the “unsubscribe” instructions provided in the email(s) you received or sending us an “opt-out” request using the contact information provided below, as applicable. [NOTE: Need to be sure the MIF has a means to collect, retain, and abide by user opt-out requests with respect to uses of PII.]
We use the Anonymous Information we collect to analyze Site visitor behavior as a measure of interest in, and use of, the Site and of the NEXSO service. This information is used to create aggregate statistics regarding, for example, when the Site is accessed, the pages which refer visitors to the Site, the type of web browsers visitors use, and which pages of the Site are viewed. These statistics help us understand how the Site is used and provide us with valuable information for improving the Site in the future.
Sharing of Information Collected Through the Site
Public Areas of the NEXSO Site
The NEXSO Site is designed as an online forum for the exchange of information, for the benefit of visitors and registered Users. Therefore, your PII will be posted on a public area of the Site, and such information and any other information you post, such as on a bulletin board, blog, or chatroom, will be visible to other Site visitors, who may then use and further disclose the PII for their own purposes. We do not exercise control over such other Site visitors’ use and disclosure of PII (which is posted in a public area of the Site), and you should be aware that other Site visitors can collect, correlate, use and disclose the PII you post, and any other information you post in the Site’s public areas. By using the Site, you acknowledge that such third-party activities are beyond the control and responsibility of the MIF and the IDB.
Legal Obligation Disclosures
We may disclose PII or other information collected through the Site in response to legal process or when we believe in good faith that the law requires it, for example, in response to a court order, subpoena, or a law enforcement agency’s request. We also may disclose such information to protect the security and operation of the Site or the rights of other Site users, and to protect ourselves and our partners, affiliates, consultants, suppliers, and providers against liability, or if we have reason to believe that someone is causing or threatening to cause injury to or interference with the MIF or IDB’s rights or property, as well as to protect against fraud.
Business Transfers
In the event that the MIF or a portion of the MIF’s assets or business is sold or assigned, merged with or otherwise transferred to a party other than the IDB, we may transfer your PII as part of the transaction. In the event such a transfer occurs, the IDB-MIF will use reasonable efforts to assure that your PII will remain subject to the same types of protection as it was prior to the transfer. However, once your PII is transferred in such a transaction, it will no longer be subject to this Privacy Policy, and you will need to review the policies and practices of the party receiving the information to learn about the protection then accorded to the PII.
Updates to Personal Information
You may access and review the PII we have collected about you, and correct or update that information, by visiting the [Registration] portion of the site, or by sending us an e-mail with requested changes at nexsoregistration@iadb.org. For your protection, we will only implement such requests with respect to the PII associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
We will endeavor to comply with your request as soon as reasonably practicable, including a request for deletion of PII from our records. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed.
Please note that we are not responsible for correcting, updating or deleting any PII information on the Site.
Data Security
We endeavor to protect the security and integrity of PII we collect by implementing physical, electronic and managerial procedures to safeguard and secure the information from loss, misuse, unauthorized access or disclosure, alteration or destruction. However, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, whether during transmission through the Internet, while stored on our data systems or otherwise maintained by us, will be absolutely safe from intrusion by others, such as hackers. This includes information provided to us by email, through direct postings on the Site, or through the “Contact Us” feature of the Site. In providing information through these channels, you should be aware that your transmission might not be secure while it is in transit, and that a third party could possibly view the information in transit.
Data Retention
RWe retain PII and Anonymous Information collected through the Site for operational, recordkeeping and legal purposes. We will retain PII about you for the period necessary to fulfill the purposes outlined in this Policy or our data retention policies, unless a longer retention period is required by law.
International Data Transfers
When you submit information to us through the Site or otherwise, that information (including any PII) will be processed in the United States. The data protection and other privacy laws of the United States may not afford the same level of protection as the laws of certain other countries. By providing personal information to IDB-MIF from outside the United States, whether directly or indirectly though the Site or otherwise, you expressly consent to the transfer of your information to the United States, in accordance with the measures of protection described in this Privacy Policy.
Privacy of Children
The NEXSO Site is not directed at minors and we do not knowingly collect from or maintain any personal information regarding persons under the age of 13.
Linked Services
The Site may contain links to third-party websites. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. The IDB-MIF does not control the websites, applications or other services that are operated by third parties and we are not responsible for the data protection and privacy practices of these websites, applications or other services. Thus, we recommend that, once you access any such other website, application or service, you familiarize yourself with the privacy policies and practices governing that other website, application or service.
Contacting Us
If you have any questions or comments regarding our privacy practices, you may contact us by email, postal mail, or phone at:
Attn: MIF Privacy Policy Specialist
Re: NEXSO Inter-American Development Bank, as Administrator of
The Multilateral Investment Fund
1300 New York Avenue, N.W.
N.W. Washington,
D.C. 20577
