The American Orthopaedic Association, which is includes all programs of
organization including the Council of Orthopaedic Residency Directors
the Bone, and affiliated organizations such as OMeGA Medical Grants
(collectively "AOA", "us" or "we") understands
that you may be concerned about the privacy of personal information
provide to us through the AOA website located at www.aoassn.org (the
"site"), and we respect your right to protect your personal
policy and practice regarding information we collect about you on the
Please contact AOA if you have additional questions about this Privacy
Information we collect
two types of information: personally identifiable information (PII) and
non-personally identifiable information (Non-PII), which is also
referred to as
aggregate and anonymous data. Generally, you may visit our website
revealing any personally identifiable information about yourself. You
option not to provide any personally identifiable information to us.
to access certain options and services we may ask you to provide
personally identifiable information and without providing such
identifiable information, you may be unable to access certain services,
offers, and specific content on the site.
information provided by you: AOA will not collect any
about you unless you provide it to us voluntarily such as when you
submit a registration for an event, submit a membership or fellowship
application, or fill out a survey. The PII you provide can include such
as your name, company, e-mail and U.S. mail addresses, your ethnicity,
credit card number, and your telephone and fax numbers.
IP addresses and logs. We employ "cookies" to collect information
about you and your usage of the site. A cookie is a small text file
placed on your computer and collects information about how you use our
also gather information about your individual use of our services, such
types of data accessed, times and volume of use, duration of sessions
similar usage or system data. In addition, we log IP addresses and
names. We cannot use this technical Non-PII to identify you personally.
However, if you choose to furnish the site with personally identifiable
information (such as your e-mail address), that information could be
the data stored in the cookie.
How we use your information
to provide information you request, provide products, programs, and
you or contact you when requested. We may also use it for reasonable
purposes, such as contacting you, via e-mail or regular mail, to
with information we believe may be of interest.
is aggregated for
system administration and to monitor the site's usage. It is utilized
measure the number of visits to our site, average time spent, number of
viewed and to monitor various other site statistics. This monitoring
evaluate how visitors use and navigate our site so we can improve the
may use this information to analyze and enhance the website.
use PII and Non-PII to investigate security breaches or cooperate with
authorities pursuant to a legal matter.
share your information
We may provide PII about you as a
customer, former customer
or user of the site to affiliates to allow affiliates to inform you
products or services that may be of benefit or interest to you and to
provide you with better service or to perform services on your behalf.
as provided below, we do
not share your PII with third parties without your permission. We may
PII you provide via the site in connection with the sale, assignment,
transfer of certain aspects of the AOA’s business or a portion of the
of our site, including a merger, consolidation, restructuring, asset
or other corporate change; or to respond to law enforcement requests;
required by applicable laws, court orders, or government regulations;
protect against misuse or unauthorized use of our site; or to protect
personal safety or property of our users or the public (among other
this means that if you provide false information or attempt to pose as
else, information about you may be disclosed as part of any
also may disclose
information to outside companies that help us bring you the products
services we offer or that are necessary to process the transaction you
For example, we may work with an outside company to: (a) process credit
transactions; (b) manage a database of customer information; (c) assist
distributing e-mails; (d) assist us with surveys, direct marketing and
collection; (e) provide us storage and analysis; (f) provide fraud
and (g) other services designed to assist us in maximizing our business
potential. We require that these outside companies agree to keep
all information we share with them and to use the information only to
their obligations in the agreements.
addition, we may disclose or
sell your PII to third-parties with your permission.
AOA may share Non-PII with business
partners, sponsors and
other third parties. We reserve the right to use, transfer, sell, and
aggregated, anonymous data about our users as a group for any business
such as analyzing usage trends and seeking compatible advertisers and
of the disclosure and use of PII
set forth below under the EU/UK/Canada Privacy Notice if you want to
sharing your information with non-affiliated third-parties, you may
email to firstname.lastname@example.org with the words OPT-OUT OF DISCLOSURE in your
line. If you select to opt-out, we will continue to share PII among our
affiliates and our affiliates may continue to use PII to perform
our behalf, to respond to communications from you, as you authorize or
or to offer you products or services. We may also continue to share PII
you with non-affiliated third-parties as permitted or required by law.
you opt-out, we can continue to use and share Non-PII with both
AOA takes reasonable steps to protect the confidentiality of your PII,
including physical, electronic, and procedural safeguards as required
We continually review our security procedures and mechanisms to ensure
reasonable protections are in place.
The website may contain links to third-party sites that are not under
control, including those of our strategic partners, sponsors and other
with information that we feel may be useful to you. AOA is not
the privacy practices, security or content of these other sites.
we recommend that you review their privacy policies.
Under the Age of 16
is not intended for children under 16 years of age. No one under age 16
provide any personal information to or on our Website. We do not
collect personal information from children under 16. If you are under
not use or provide any information on our Website or on or through any
features/register on our Website, make any purchases through our
any of the interactive or public comment features of our Website or
information about yourself to us, including your name, address,
number, e-mail address or any screen name or user name you may use. If
we have collected or received personal information from a child under
without verification of parental consent, we will delete that
you believe we might have any information from or about a child under
please contact us at email@example.com.
and changing the date on this page noting when it was last updated.
continued use of the site following the posting of any changes shall
EU/UK/Canada Privacy Notice
you are a
resident of the European Union (EU)/European Economic Area (EEA),
Kingdom or Canada whose personal information we collect, the following
additional information applies to you.
you are an EU/ EEA, UK, or Canada resident and AOA knowingly collects
personal information (also called 'personal data'), we will do so in
with applicable laws that regulate data protection and privacy. This
without limitation, the EU General Data Protection Regulation
('GDPR') and EU member state national laws that implement or regulate
collection, processing and privacy of your personal data (together, 'EU
EU/UK/Canada privacy notice ('EU/UK/Canada Privacy Notice') which
required under EU Data Protection Law on how we handle or process the
data we collect and who we may share it with.
Privacy Notice also provides information on your legal rights under EU
Protection Law and how you can exercise them.
How personal data is collected
Because of the global nature of our organization and its network, AOA
and process personal data that is collected from programs, fellowships
partner organizations around the world, including within the EU/UK/EEA.
also means that if you are a member or individual contact of this
resident in the EU/UK/EEA, your personal data may be transferred from
to AOA headquarters in the United States.
data privacy laws are currently not considered to meet the same legal
of protection for personal data as set out under EU Data Protection
However, in order to safeguard personal data received from the
only allow such a transfer of personal data to the US or other third
under an approved contract or another appropriate mechanism which is
authorized under EU Data Protection Law.
is to make sure that the personal data that AOA receives and processes
as it relates to residents of the EU/UK/EEA) is properly safeguarded in
accordance with similar legal standards of privacy you would enjoy
Data Protection Law.
- If AOA
provides direct marketing communications to individuals in the
regarding services and/or events which may be of interest, this will be
accordance with EU Data Protection Law, and in particular where we
individuals for direct marketing purposes by SMS, email, fax, social
and/or any other electronic communication channels, this will only be
individual's consent or in relation to similar services to services
individual has purchased (or made direct enquiries about purchasing)
Individuals are also free to object or withdraw consent to receive
marketing from us at any time, by contacting us using the email address
The lawful grounds on which we collect and process personal data
process your personal data for the above purposes, relying on one or
the following lawful grounds under EU Data Protection Law:
where you have freely provided your specific, informed and unambiguous
for AOA to process your personal data for particular purposes
where we agree to provide services to you, in order to set up and
contractual obligations to you and/or enforce our rights
where we need to process and use your personal data in connection with
legitimate interests as a global network and being able to effectively
and operate our organization in a consistent manner across all
will always seek to pursue these legitimate interests in a way that
unduly infringe on your legal rights and freedoms and, in particular,
right to privacy, and/or
where we need to comply with a legal obligation or for the purpose of
able to establish, exercise or defend legal claims.
also note that some of the personal data we receive and that we process
include what is known as 'sensitive' or 'special category' personal
you, for example, information regarding your gender, ethnic origin or
political, philosophical and religious beliefs. If the AOA processes
sensitive or special category data we will only do this in specific
you have provided this with your explicit consent for us to use it: or,
there is a legal obligation on us to process such data in accordance
Data Protection Law
it is needed to protect your vital interests (or those of someone else)
in a medical emergency or,
where you have clearly chosen to publicize such information or,
where needed in connection with a legal claim that we have or may be
Disclosing your personal data to third parties
- We may
disclose your personal data to certain third party organizations who
processing data solely in accordance with our instructions (called
processors') such as companies and/or organizations that support our
and operations (for example providers of web or database hosting, IT
payment providers, event organizers, agencies we use to conduct fraud
mail management service providers) as well as professionals we use such
lawyers, insurers, auditors or accountants. We only use those data
who can guarantee to us that adequate safeguards are put in place by
protect the personal data they process on our behalf.
- We may
also disclose your personal data to third parties who make their own
determination as to how they process your personal data and for what
(called “data controllers”). The external third party data
identified above may handle your personal data in accordance with their
chosen procedures and you should check the relevant privacy policies of
companies or organizations to understand how they may use your personal
than as described above, we will treat your personal data as private
not routinely disclose it to third parties without you knowing about
exceptions are in relation to legal proceedings or where we are legally
required to do so and cannot tell you (such as a criminal
always aim to ensure that your personal data is only used by third
deal with for lawful purposes and who observe the principles of EU Data
How long we retain your personal data for
retains personal data identifying you for as long as necessary in the
circumstances - for instance, as long you are a member of the AOA or
relationship with one of our programs for a reasonable period to send
marketing or other materials where we have regular contact with you, or
be needed to enforce or defend contract claims or as is required by
has adopted a data retention policy for EU / UK residents (which we may
available on request) that sets out the different periods we may retain
personal data for in respect of relevant purposes in accordance with
under EU Data Protection Law. The criteria we use for determining the
retention and disposal periods we adopt are based on the purpose for
hold data and the reasonable expectations of those whose personal data
collect in these circumstances, taking into account various
requirements and guidance issued by relevant EU regulatory authorities.
accordance with the above retention policy, the personal data that we
need will be disposed of and/or anonymized so you can no longer be
Your personal data rights
accordance with your legal rights under EU Data Protection Law, you
'subject access request' right under which can request information
personal data that we hold about you, what we use that personal data
who it may be disclosed to as well as certain other information.
Usually we will have one month to respond to a subject access request.
we reserve the right to verify your identity and we may, in case of
requests, require a further two months to respond. We may also charge
administrative time in dealing with any manifestly unreasonable or
requests. We may also require further information to locate the
information you seek and certain legal exemptions under EU Data
may apply when responding to your subject access request.
EU Data Protection Law. EU/EEA residents also have the following
are exercisable by making a request to us in writing:
that we correct personal data that we hold about you which is
that we erase your personal data without undue delay if we no longer
hold or process it
to object to any automated processing (if applicable) that we carry out
relation to your personal data.
to object to our use of your personal data for direct marketing
to object and/or to restrict the use of your personal data for purpose
than those set out above unless we have a compelling legitimate reason,
that we transfer personal data to another party where the personal data
been collected with your consent or is being used to perform contract
and is being processed by automated means.
- So we
can fully comply, please note that these requests may also be forwarded
third party data processors who are involved in the processing of your
data on our behalf.
- If you
would like to exercise any of the rights set out above, please contact
the address below.
- If you
make a request and are not satisfied with our response, or believe that
illegally processing your personal data, you have the right to lodge a
to a supervisory authority including, without limitation, the EU Member
of his or her habitual residence, place of work or place of the alleged
The site is operated and controlled by the American Orthopaedic
the United States, and is intended for use only by people within the
States. We make no representations that any materials on the site are
appropriate for use outside of the United States.
Under California Civil Code sections 1798.83-1798.84, California
entitled to ask AOA for a notice describing what categories of personal
customer information we share with third parties or affiliates for
parties or affiliates' direct marketing purposes. That notice will
categories of information shared and will include a list of the third
and affiliates with whom it was shared, along with their names and
If you are a California resident and would like a copy of this notice,
submit a written request to the address below. Please note that it may
days from receipt of your written request to receive the notice.
9400 West Higgins Road, Suite 205
Rosemont, IL 60018
The AOA will disclose personal information when required by law or in
good-faith belief that such action is necessary to: conform to the
the law or comply with a legal process served on the AOA, protect and
the rights or property of the AOA, or visitors to the AOA web site,
persons who may be violating the law, the legal notice, or the rights
parties, cooperate with the investigations of purported unlawful
It is the policy of the AOA to allow members to inspect the following
of the organization:
• IRS Form 990
• Original applications for tax-exempt status
• Articles of incorporation
• Audited financial statements
Access will be granted at AOA Headquarters at a mutually agreed upon
responsible AOA employee will remain in the presence of the
requesting access to this information. Individuals will be allowed a
amount of time to review the records, but access to copying machines
like may be denied.
AOA legal counsel is Paula Goedert, Esq., Barnes and Thornburg,
Contact information will not be shared or sold to third parties for any
Questions or Comments
wish to review and correct your personally identifiable information
held by AOA,
please contact Sonia Armendariz, Data Protection Officer, American
Association, 9400 West Higgins Road, Suite 205, Rosemont, IL 60018, at