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Privacy Policy

Information Security Policy, Northern Initiatives’ Website Privacy Policy

June 2, 2023

This version was last updated on June 2, 2023.

 

INTRODUCTION  

Welcome to our Privacy Policy for our website, www.initiateprosperity.org operated by Northern Great Lakes Initiatives (“Northern Initiatives” “NI” or “we” or “us”) in the United States and its related domains, Initiate software platform, social media channels, mobile application, services, information, web postings, products and tools (collectively, “Website” or “Service(s)”).

 

We respect your privacy and the privacy of your employees, contractors, and agents, and we are committed to protecting personal data we obtain through your use of the Website and Services. This Privacy Policy will inform you as to how we look after personal data when you visit our Website or use our Services (regardless of where you visit it from) and tell you about your privacy rights.

 

By using our Website, you consent to the data practices described in this Privacy Policy and you agree to the Website Terms of Use as if fully incorporated herein. If you do not agree with the data practices described in this Privacy Policy, you should not use our Website.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW WE COLLECT YOUR PERSONAL DATA

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. WEB ACCESSIBILITY STATEMENT

7. DATA SECURITY

8. DATA RETENTION

9. YOUR RIGHTS

10. CALIFORNIA RESIDENT’S PRIVACY RIGHTS

 

1. IMPORTANT INFORMATION AND WHO WE ARE  

Northern Initiatives provides an effective, hands-on set of training videos, tools, and templates. Exclusively available to small businesses working with participating organizations.

Initiate is an online business resource with over 300 interactive tools, templates, videos, and guides. Our user-friendly platform benefits aspiring and existing small business owners. Initiate’s tools guide you through topics that will quickly advance your knowledge in the areas of Money, Marketing, and Management.

Purpose of this Privacy Policy 

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of this Website, including any data you may provide through this Website when you sign up to our newsletter, or purchase a product or service.

 

This Website is not intended for children and we do not knowingly collect data relating to children consistent with the U.S. Children’s Online Privacy Protection Act. If we learn that we have received information directly from a child under age 13 without the parent or legal guardian’s verified consent, we will use that information only to respond to the child/parent/guardian to inform the child that he or she may not use the Website.

 

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other policies and is not intended to override them.

 

Northern Initiatives Contact Information

Our contact details are:

Email address: info@initiateprosperity.org

Postal address: 101 W. Washington St., Suite 9, Marquette, MI 49855

 

Changes to this Privacy Policy and Your Duty to Notify Us of Changes  

We will notify you of any changes to this Privacy Policy. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third-Party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU  

Personal data, or personal information, means any information about an individual from which that person can be identified.

 

We or our service providers may collect, use, store and transfer different kinds of personal data about you or your employees, contractors, or agents or other Personal Data you submit to us, which we have grouped together follows:

 

  • Identity Data includes first name, last name, username or similar identifier, ethnicity, gender, job title, and date of birth.

  • Contact Data includes billing address, delivery address, email address, and telephone numbers.

  • Financial Data includes payment card details, account numbers, and expiration dates.

  • Company Data includes information regarding your company such as your industry, business address, total number of employees, years in business, and annual revenue.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.

  • Usage Data includes information about how you use our Website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3. HOW WE COLLECT YOUR PERSONAL DATA  

We use different methods to collect data from and about you including through:

 

Direct interactions. You may give us your personal data by using the Website or filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • use the Website or Services;

  • use the Initiate software platform;

  • apply for our products or services;

  • create an account on our Website;

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • conduct a survey; or

  • give us some feedback.

 

Automated technologies or interactions. As you interact with our Website, we may automatically collect data about your equipment, browsing actions and patterns, action items completed, hours of training, and logins.

Third-party sources. We may receive personal data about you from various third parties including our third-party service providers.  We employ other companies and individuals to perform functions upon our behalf. Examples include storing and analyzing data, providing search results and links (including paid listings and links), providing customer service, and payment processing. They have access to user information needed to perform their functions, but may not use it for other purposes.

 

Cookies Policy

We may place “cookies” on the browser of your computer. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. Cookies may enhance the convenience and use of the Website. For example, the information provided through cookies may be used to recognize you as a previous user of the Website (so you do not have to enter your personal information every time), offer personalized information for your use, and otherwise facilitate your experience using the Website. You may choose to decline cookies if your browser permits, but doing so may affect your ability to access or use certain features of the Website.

 

Web Beacons

We may also utilize web beacons on our Website. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. The information collected through these automated means may include information that we gather and store about your visit to, and use of, the Website, such as your IP address, type of browser and operating system used, date and time you access the Website, pages you visit, and, if you linked to the Website from another website, the address of that website. This data does not include personal information and is not treated as personal information under this Privacy Policy, but it may include the IP address of your device. We may link an IP address to information that is personally identifiable.

 

4. HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: (a) where we need to perform the contract we are about to enter into or have entered into with you; (b) where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests; (c) where we need to comply with a legal or regulatory obligation. We may use your data in the following ways:

 

  • To provide the Services to you;

  • To register you as a new guest;

  • To process and deliver your order, manage payments, fees, and charges;

  • To manage our relationship with you;

  • To enable you to complete a survey;

  • To administer and protect our Website;

  • To deliver relevant Website content and advertisements to you;

  • To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences;

  • To make suggestions and recommendations to you about goods or services that may be of interest to you.

 

Marketing and Outreach  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. You can manage the marketing and outreach we provide to you by opting out, which is described in the “Opting Out” section below.

 

Opting Out

You can ask us to stop sending you marketing messages at any time by replying to a marketing email with “unsubscribe” in the subject line, clicking “unsubscribe” in the marketing email itself, or by contacting us at any time.

5. DISCLOSURES OF YOUR PERSONAL DATA  

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.  Those trusted third-party partners may:

 

  • Provide you and members with various services

  • Provide database maintenance and security

  • Help us manage transactions

  • Help us process and fulfill orders or requests

 

We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

 

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your Personal Information may be transferred as part of such a transaction, as permitted by law and/or contract. By providing your personal information to us, you consent to such a transfer.

 

6. WEB ACCESSIBILITY STATEMENT

We are committed to making the Website’s content accessible and user friendly to everyone. If you are having difficulty viewing or navigating the content on this website, or notice any content, feature, or functionality that you believe is not fully accessible to people with disabilities, please call us at 906-228-5571 or email us at info@initiateprosperity.org with “Assist with Access” in the subject line and provide a description of the specific feature you feel is not fully accessible or a suggestion for improvement.

 

7. DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. DATA RETENTION  

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

9. YOUR RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your employees, contractors, and/or agents may have similar rights.

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent to us processing your personal data.

 

If you wish to exercise any of the rights set out above, or if you have a complaint please Contact us.  NI commits to resolve complaints about our collection or use of your personal information. Inquiries or complaints regarding the processing of personal data should first be directed to NI at info@initiateprosperity.org.

 

10. CALIFORNIA RESIDENT’S PRIVACY RIGHTS

NI does not track its Users over time and across third-party websites to provide targeted advertising and therefore or does not respond to Do Not Track (DNT) signals. 

California’s “Shine the Light” law permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us at info@initiateprosperity.org. This request may be made no more than once per calendar year.

 

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