North Mill Capital’s Privacy Principles
North Mill Capital follows the following principles in order to protect your privacy:
- We do not collect any more personally identifiable information about you than is necessary;
- We do not keep your personally identifiable information if it is no longer needed; and
Information We Collect
PERSONALLY IDENTIFIABLE INFORMATION
We may collect personally identifiable information from Users in a variety of ways, including, but not limited to, when Users visit the Site, register on the Site, subscribe to a newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features, or resources we make available through our Services. Users may be asked for, as appropriate, name, email address, mailing address, date of birth, social security number, employer identification number, and telephone number. Users can always refuse to supply the personally identifiable information that we request, except that it may prevent them from engaging in certain Site-related activities or receiving certain Services.
NON-PERSONALLY IDENTIFIABLE INFORMATION
COOKIES AND OTHER TRACKING TECHNOLOGIES
As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Site.
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. We use session cookies to track your login status. This cookie is only ever transmitted over HTTPS. A persistent cookie remains on your hard drive for an extended period of time. We use persistent cookies to determine from where you were referred to our Sites so that we may provide commissions or referral fees and recognize the last user ID that you used to log in. We use, among others, Google Analytics and Google Adwords web analytics and marketing tools to help us directly market to and understand how visitors engage with the Site.
You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. You can go to www.aboutcookies.org for more information on cookies, including how to disable them. If you choose to disable cookies, it may limit your use of certain features or functions on our Sites or Service. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
HOW WE USE PERSONALLY IDENTIFIABLE INFORMATION
North Mill Capital may collect and use Users’ personally identifiable information for the following purposes:
- To process transactions Information you provide allows us to process transactions made on the Site or as otherwise necessary for performance of our contractual obligations to you, including as applicable, order confirmation, billing, and delivering products or services.
- To improve customer service Information you provide helps us respond to your customer service requests and support needs more efficiently. We will do this on the basis of our legitimate interests.
- To personalize User experience We may use information in the aggregate to understand how our Users as a group use the Services. We will do this on the basis of our legitimate business interests.
- To improve our Services We may use feedback you provide to improve our Services. We will do this on the basis of our legitimate business interests.
- To run a promotion, contest, survey, or other Site feature With your consent, we will use your personally identifiable information to keep you informed by email, text, web, or telephone about our products and services, including tailored special offers, discounts, promotions, events, and competitions. You are free to opt out from receiving such communications at any time.
- To communicate directly with you We may use your personally identifiable information to respond to your inquiries, questions, and/or other requests. We do this on the basis of our contractual obligations to you, our legal obligations, and our legitimate interests.
- To share offers from third parties that may be of interest to you With your consent, we may use your information to let you know about offers, programs, products, or services, from us or third parties, that may be of interest to you.
- To fulfill any other purpose for which you provide personally identifiable information We may use your personally identifiable information for purposes that we make known to you at the time of collection of such information or otherwise upon your consent.
HOW WE PROTECT YOUR INFORMATION
The security of your personally identifiable information is important to us. We have adopted generally accepted industry standards in connection with our data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personally identifiable information, username, password, transaction information, and data stored on the Site. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personally identifiable information, we cannot guarantee its absolute security.
DISCLOSURE OF YOUR PERSONALLY IDENTIFIABLE INFORMATION
We may disclose aggregated information about our Users, and information that does not identify any individual user, without restriction. We may disclose personally identifiable information about you in the following ways:
- Agents and Service Providers. We may disclose personally identifiable information about you to contractors, service providers, and other third parties we use to support our business, provide the Services, and who complete transactions or perform services on our behalf or for your benefit. For example, we use a third party processor to process payments for the Services.
- Legal Process. We may disclose personally identifiable information about you as required by law, such as to comply with a subpoena or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- Consent. We may disclose personally identifiable information about you in additional ways, with your consent.
You have the right to request a copy of any personally identifiable information that we hold about you. We may request proof of your identity before sharing such information. If you discover that the information we hold about you is incorrect or out of date, you may also ask us to correct that information.
You may ask us to delete the personally identifiable data we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we are fulfilling a transaction or have a legal basis to retain the information, however please contact us to discuss how we can assist you with your request.
When we process your information on the basis that you have consented to such processing, you may withdraw your consent, or ask us to stop or restrict processing the personally identifiable information we have about you.
We will retain your information for as long as your account is active or as needed to fulfill your requests, provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.
If you receive marketing emails from us, you can unsubscribe to our emails at any time by clicking “unsubscribe” within each email. You may not opt-out of service-related communications, which are not promotional in nature.
Users may find advertising or other content on the Site that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from the Site. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing on and interacting with any other website, including websites which have a link to the Site, are subject to that website’s own terms and policies.
ADVERTISING AND RE-MARKETING
We use third parties’ re-marketing technology to market the Site across the Internet. We place a cookie on your browser, and then a third party reads these cookies and may serve an ad on a third-party website, after you have visited the Site.
HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services.
CHILDREN UNDER THE AGE OF 13
The Services are not directed to, and North Mill Capital does not knowingly collect or solicit personally identifiable information from, children under the age of 13. If we learn we have collected or received personally identifiable information from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us at firstname.lastname@example.org.
INTERNATIONAL DATA TRANSFERS
North Mill Capital is located in, and the Site and Services are provided from, the United States of America. Wherever you use our Site or access our Services, you understand and acknowledge that we may transfer, process, and store information about you in the United States and other countries, both within and outside of the European Economic Area. These countries may have different data protection laws from those in the country in which you reside.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section § 1798.83 permits Users that are California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com
North Mill Capital
21 Alexander Road, Ste. 130 Princeton, NJ 08540
Attention: Privacy Officer
Last updated: July 2018