Scope of this Policy
Our “Offline Services”
- In-person services you use when you participate in one of our in-person programs, such as the “Dairy princess program” or interact with us at an event (collectively, “Events and Programs”).
Our “Digital Services”
- Our websites, including www.midwestdairy.com, www.midwestdairycheckoff.com, and www.midwestdairy.org; and
- Our social media accounts, including Facebook, Instagram, LinkedIn, Pinterest, Twitter, and YouTube, including all content available through these platforms.
How to Contact Us
The controller of your Personal Information under this Policy is Midwest Dairy Association. You may contact our data privacy team as follows:
|Physical Address:||Midwest Dairy|
2015 Rice Street
St. Paul, MN 55113
|Marketing Choices; Information Updates; and General Inquiries:||Email email@example.com, call 800-642-3895, or visit our Contact Us page.|
Categories and Sources of Personal Information
The following describes how we collect data relating to identified or identifiable individuals (“Personal Information”).
Categories of Personal Information We Process
- Audio/Visual Information – Recordings and images collected at our Events and Programs, as well as audio files and records, such as voicemails, call recordings, and the like.
- Biographical Information – Information relating to professional and employment history, qualifications, and similar biographic information.
- Transaction Information – Information about the Service we provide to you or the transactions you make with us.
- Contact Information – Identity Information we can use to contact you, such as email and physical addresses, phone numbers, and social media or communications platform usernames/handles.
- Device / Network Information – Browsing history, search history, and information regarding your interaction with a website, application, or advertisement (e.g. IP Address, MAC Address, SSIDs, application ID/AdID/IDFA, session navigation history and similar browsing metadata, and other information generated through applications and browsers, including cookies and similar technologies or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, first party cookies, third party cookies, web beacons, clear gifs, and pixel tags.
- Identity Information – Information such as your name, address, email address, telephone number, gender, date of birth, age and/or age range, account login details, e.g. username and password, avatar, or other account handles/usernames, and information needed for employment verification if you apply to work for Midwest Dairy such as date of birth, social security number, identity documentation, and citizenship information.
- Inference Information – Personal Information generated reflecting your preferences, characteristics, predispositions, behavior, demographics, household characteristics, market segments, likes, favorites, and other data or analytics.
- General Location Information – e.g. location information derived from social media tags/posts.
- User Content – Unstructured/free-form information that may include any category of Personal Information, e.g. data that you give us in free text fields such as comment boxes.
Sources of Personal Information We Process
We collect Personal Information from various sources, which include:
- Information you provide us – We receive Personal Information when you provide it to us, when you purchase our products or services, complete a transaction via our Service, or when you otherwise use our Service.
- Information we collect automatically – We collect Personal Information about or generated by any device used to access our Digital Services.
- Partners and Service Providers – We receive Personal Information from certain third-party partners or service providers, including teachers, school foodservice personnel, healthcare professionals, dairy farmers, dairy industry representatives, who transfer Personal Information to us when you interact with our joint services or when service providers perform services on our behalf.
- Advertisers – We receive Personal Information from ad networks, Targeted Advertising vendors, market research, and social media companies or similar companies who provide us with additional Personal Information, e.g. Inference Information.
- Social media companies – We receive Personal Information from social media companies when you use social media sign on, or interact with that social media company on or in connection with our Service. These include:
- Facebook Pixel. With your permission, we also use the Facebook Pixel, a service of Meta and Facebook. This tool allows us to follow the actions of users after they are redirected to our Service by clicking on a Facebook advertisement. This process allows us to track and record the efficacy of our Facebook advertising, thus improving the user experience. The Facebook Pixel also allows us to retarget you with further advertisements on Facebook through the use of Custom Audiences. Visit your privacy choices below to control how we receive your Personal Information through the Facebook Pixel.
- Information we create or infer – We may create and infer Personal Information such as Inference Information or Aggregate Information based on our observations or analysis of other Personal Information processed under this Policy, and we may correlate this information with other information we process about you.
Data Processing Context / Notice at Collection
Promotional Items and Resources
We process Identity Information, Contact Information, Transaction Information, Device/Network Information, and User Content when you download resources or order our free promotional items or resources for your school, event, or program.
We use this Personal Information to provide the promotional items or resources you request, and for our Business Purposes. We may process Identity Information, Transaction Information, and Contact Information for Commercial Purposes (which may include data sales/sharing).
Events, Grants, and Programs
We process Identity Information, Contact Information, Transaction Information, and User Content when you register for and attend one of our events, participate in one of our programs, apply for a grant, or request a visit from one of our dairy ambassadors, such as a dairy princess. We also process Biographical Information if you apply to be dairy ambassador. We may collect Audio/Visual Information in the form of promotional photos or testimonial videos.
We process this Personal Information to provide updates about the event, as well as for our Business Purposes. We use Identity Information, Inference Information, Transaction Information, and Contact Information collected in this context for our Commercial Purposes (which may include data sales/sharing).
We process Device/Network Information, Contact Information, Identity Information, and Inference Information in connection with marketing emails, our newsletter, giveaway communications, or similar communications, and when you open or interact with those communications. You may receive marketing communications if you consent and, in some jurisdictions, as a result of account registration or a purchase.
We process this Personal Information to contact you about relevant products or services and for our Business Purposes. We may use this data for our Commercial Purposes (which may include data sales/sharing). See your Rights & Choices to limit or opt out of this processing.
We process Device/Network Information, Contact Information, Identity Information, General Location Information, and Inference Information. You may also be able to register for an account, order promotional items and resources, or sign-up for an event or program through our Digital Services.
We use this Personal Information as necessary to operate our Digital Services, such as keeping you logged in, delivering pages, for our Business Purposes, and our other legitimate interests, such as:
- ensuring the security of our websites and other technology systems; and
- analyzing the use of our Service, including navigation patterns, clicks, etc. to help understand and make improvements to the Service.
We may process this Personal Information for our Commercial Purposes (which may include data sales/sharing).
Cookies and Other Tracking Technologies
- for “essential” purposes necessary for our Digital Services to operate (such as maintaining user sessions, content delivery, and the like);
- for “functional” purposes, such as to enable certain features of our Digital Services (for example, to allow a customer to maintain an online shopping cart);
- for “analytics” purposes and to improve our Digital Services, such as to analyze the traffic to and on our Digital Services (for example, we can count how many people have looked at a specific page, or see how visitors move around the website when they use it, to distinguish unique visits/visitors to our Digital Services, and what website they visited prior to visiting our website, and use this information to understand user behaviors and improve the design and functionality of the Service);
- for “retargeting,” Targeted Advertising, or other advertising and marketing purposes, including technologies that process Inference Information or other information so that we can deliver, buy, or target advertisements which are more likely to be of interest to you; and
- for “social media” e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Service or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter.
We may also process this Personal Information for our Business Purposes and Commercial Purposes (which may include data sales/sharing). See your Rights & Choices for information regarding opt-out rights for cookies and similar technologies.
We use the following third party cookies on our Service:
- Facebook Custom Audiences. Facebook Custom Audiences are an advertising service provided by Facebook. For more information on how Facebook collects information using cookies, please visit: https://www.facebook.com/full_data_use_policy/.
- LinkedIn Ads. LinkedIn Ads is a targeted advertising service provided by LinkedIn. For more information on how LinkedIn Ads works visit: https://www.linkedin.com/legal/sas-terms. To learn more about LinkedIn’s privacy practices, visit: https://www.linkedin.com/legal/privacy-policy?trk=content_footer-privacy-policy.
Third parties may view, edit, or set their own cookies or place web beacons on our Service. We, or third party providers, may be able to use these technologies to identify you across platforms, devices, sites, and services. Third parties may engage in Targeted Advertising using this data. Third parties have their own privacy policies and their processing is not subject to this Policy.
Contests and Promotions
We may collect and process Identity Information, Inference Information, certain Contact Information, and User Content when you enter a contest/sweepstakes or take part in a promotion. Some contests programs, offers, or sweepstakes may have additional terms and privacy policies that you should review.
We process this Personal Information as necessary to provide the contest/promotion, notify you if you have won, or to process delivery of a prize, for our Business Purposes, and other legitimate interests, such as:
- To verify your identity for authentication, anti-fraud, and security purposes;
- To improve our Service and to create a personalized user experience; and
- To contact you about relevant products or services, and in connection with marketing communications and Targeted Advertising.
We may process Identity Information, Contact Information, and User Content information for our Commercial Purposes (which may include data sales/sharing).
Your Personal Information may be public. If you win a contest/sweepstakes, we or our third-party partners may publicly post some of your information. We do not post Personal Information without consent where required by law.
Public Posts/Farmer Stories
We process Identity Information, Inference Information, Contact Information, and User Content you post (e.g. comments, forum and social media posts, etc.) on our Digital Services. We also process Identity Information, Contact Information, User Content, and Audio/Visual Information if you provide a testimonial or consent to be included in our marketing materials, such as Farmer Stories.
Posts and testimonials may be public or reposted on our Service. Content you provide may be publicly-available when you post it on our Service, or in some cases, if you reference, engage, or tag our official social media accounts or communications platforms.
Contact Us; Support
We collect and process Identity Information, Contact Information, and User Content when you contact us, e.g. through a contact us form, for support, or when you report a problem with our Service. If you call us via phone, we may collect Audio/Visual Information from the call recording.
We process this Personal Information to respond to your request, and communicate with you, as appropriate, and for our Business Purposes. If you consent or if permitted by law, we may use Identity Information and Contact Information to send you marketing communications and for our Commercial Purposes (which may include data sales/sharing).
We process Identity Information, Contact Information, Biographical Information, Inference Information, and User Content in connection with your application for employment.
We process this Personal Information as necessary to evaluate, establish, and maintain the employment or internship relationship, and for our Business Purposes.
We and our Service Providers process Personal Information we hold for numerous business purposes, depending on the context of collection, your Rights & Choices, and our legitimate interests. We generally process Personal Information for the following “Business Purposes.”
We process Personal Information as necessary to provide our Service and the products and services you purchase or request. For example, we process Personal Information to deliver educational materials to your school, provide promotional materials for your industry event, or otherwise as otherwise necessary to fulfill our contractual obligations to you, provide you with the information, features, and services you request, and create relevant documentation.
Internal Processing and Service Improvement
We may use any Personal Information we process through our Service as necessary in connection with our legitimate interests in improving the design of our Service, understanding how our Service is used or functions, for customer service purposes, for internal research, technical or feature development, to track service use, QA and debugging, audits, and similar purposes.
Security and Incident Detection
We may process Personal Information in connection with our legitimate interest in ensuring that our Service and Events and Programs are secure, in identifying and preventing crime, preventing fraud, verifying or authenticating users/individuals, and in ensuring the safety of our users. Similarly, we process Personal Information on our Digital Services as necessary to detect security incidents and to protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns, and characteristics, maintain and analyze logs and process similar Personal Information in connection with our information security activities.
We process certain Personal Information as necessary in connection with our legitimate interest in personalizing our Digital Services. For example, aspects of the Digital Services may change so they are more relevant to you. We may personalize based on Inference Information and your current interactions with the Service, or obtain it from third parties, using Personal Information we hold about you. We may also personalize where permitted by law, e.g. by displaying your name and other appearance or display preferences, to display content that you have interacted with in the past, or to display content that we think may be of interest to you based on your interactions with our Digital Services and other content.
Compliance, Health, Safety, Public Interest
We may also process Personal Information as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law, for the establishment and defense of legal claims, where we must comply with requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process Personal Information to protect the vital interests of individuals, or on certain public interest grounds, each to the extent required or permitted under applicable law. Please see the Disclosure/Sharing of Personal Information section for more information about how we disclose Personal Information in extraordinary circumstances.
We and certain third parties process Personal Information to further our commercial or economic interests (“Commercial Purposes”) depending on the context of collection and your Rights & Choices.
Personalized Marketing Communications
We may personalize Marketing Communications based on the Personal Information we collect and process.
In some jurisdictions, we may engage in advertising targeted to your interests based on Personal Information that we obtain or infer from your activities across non-affiliated websites, applications, or services in order to predict your preferences or interests (“Targeted Advertising”). This form of advertising includes various parties and service providers, including third party data controllers, engaged in the processing of Personal Information in connection with advertising. These parties may be able to identify you across sites, devices, and over time.
We generally use Targeted Advertising to raise awareness of our Service, to market our Service and third-party goods and services, and to send marketing communications, including by creating custom marketing audiences on third-party websites or social media platforms.
Disclosure/Sharing of Personal Information
We may share Personal Information with the following categories of third-party recipients and/or for the following reasons:
- Affiliates – We may share Personal Information internally with our current and future subsidiaries and affiliates.
- Service Providers – We may share your Personal Information with service providers who provide certain services or process data on our behalf in connection with our general business operations, service fulfillment and improvements, to enable certain features, and in connection with our Business Purposes.
- Sponsors, Advertisers, and Social Media Platforms – We may share certain Personal Information with social media platforms, advertisers, ad exchanges, data management platforms, or sponsors in support of our Business Purposes and Commercial Purposes. We may allow these third parties to operate through our Service.
- Partners – We may offer you the opportunity to use services operated by third parties (such as our event partners or sponsors), and if you choose to use these services, we will disclose the Personal Information that you direct us to provide to them or as is appropriate to fulfill your requests. You may also direct us to disclose this data to or interact with these third parties as part of attending an event or program. However, in other cases, these parties may also receive data for Commercial Purposes.
- Data Aggregators – We may share Personal Information with data aggregators in support of our Commercial Purposes. These disclosures can help better personalize our Service and the services of third parties and help ensure that you see advertisements that are more relevant to your interests.
- Successors – We may share Personal Information in the event of a potential or actual merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Users is among the assets transferred.
Your Rights and Choices
You may send us an email via our contact link to correct any Personal Information that you have provided to us or with any other requests related to your Personal Information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your California Privacy Rights
Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes, and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at firstname.lastname@example.org by writing us at Midwest Dairy, 2015 Rice Street, St. Paul, MN 55113.
Your Nevada Privacy Rights
The Nevada Revised Statutes (NRS 603A.300 et seq.) permit a Nevada consumer to direct an operator of an Internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. You may submit a request pursuant to this directive by emailing us at email@example.com. We will provide further information about how we verify the authenticity of the request and your identity.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email (for email), by responding with “OPT-OUT,” STOP, or other supported unsubscribe message (for SMS), by adjusting the push message settings for our mobile apps using your device operating system (for push notifications), or for other communications, by contacting us using the information above. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.
Cookies, Similar Technologies, and Targeted Advertising
Targeted Advertising – You may opt out or withdraw your consent to Targeted Advertising by submitting requests to third party partners, including for the vendors listed below:
- Google Ads
- Facebook Custom Audience Pixel
- Digital Advertising Alliance’s opt-out
- Network Advertising Initiative opt-out
Do-Not-Track – Our Service does not respond to your browser’s do-not-track request which means that we or our service providers or other third parties with which we are working may collect information about your online activity both during and after your use of the Service.
We implement and maintain commercially reasonable security measures to secure your Personal Information from unauthorized processing. While we endeavor to protect our Service and your Personal Information unauthorized access, use, modification and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.
We cannot guarantee that transmissions of your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.
- Retention periods established under applicable law;
- Industry best practices;
- Whether the purpose of processing is reasonably likely to justify further processing;
- Risks to individual privacy in continued processing;
- IT systems design considerations/limitations; and
- The costs associated continued processing, retention, and deletion.
We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.
Our Service is neither directed at nor intended for use by persons under the age of 16 in the US. If a child under the age of 16 has provided us with Personal Information and if the parent or guardian of the child would like the information submitted by the child deleted from our database, we ask that a parent or guardian of the child contact us.
Third Party Websites and Mobile Apps
This Policy does not apply to third party websites, products, or services. Third parties may operate or develop some Midwest Dairy websites and mobile apps, may operate or host a contest/sweepstakes on our Service. In these cases, the terms, conditions, and privacy practices of the third party, not those of Midwest Dairy, may govern your transactions, and we may have no control over the Personal Information collected.
International Transfers of Your Personal Information
We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Information may be transferred to the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Information in other countries. Contact us for more information regarding transfers of data to the U.S.
Last updated July 5, 2023.