November Project Privacy Notice
We at November Project respect your privacy when you use our Services. “November Project”, “we” or “us” all refer to November Project, Inc. and its affiliated entities, and their founders, directors, executives, employees, agents and other personnel. “Services” means our services including our websites and activities that we organize. This Privacy Notice tells you what information we collect when you use our Services, how we use it, and your rights pertaining to your information. Whenever you use any of our Services, including our website, you agree to this Privacy Notice. If you disagree, then you may not use our Services.
If you are currently in Europe, please review the information that we need to give you (Section G). We say ‘Europe’ to mean both the European Union (EU) and the European Economic Area (EEA).
A. WHAT INFORMATION DO WE COLLECT AND WHY?
In this Privacy Notice, we say “personal information” or “your information” to mean information connected with you as an individual person.
1. Information that we collect
Information you give us. When you sign up with us on our website, we ask you to provide your full name, email address, gender, geographic information, and other information. In addition, if you join our workouts in person and use a sign-up sheet, we may collect information from those sheets and store that information together with other information. In short, if you provide us your information when you interact with us, we may collect it. We collect your information to the extent we believe it necessary to provide you the Services that you request from us. You are not obligated to give your information. But if you do not, we may not be able to provide you some or any of the Services you request.
Internet, technical and device data. The devices you use to interact with us (including computer, web browser, online and mobile technologies) may automatically send us information about the device and software you are using. This data may even be tied to your IP address or internet routing information which we may see.
Workout activities. We may track your workout activities while you use our website, or when you ask us to. For example, we might track your workouts with us and provide a web-based workout leaderboard (which our site may call a “tracker”).
Microphone, camera, and other mobile device sensors. If you send us material that includes device sensor data (such as geolocation coordinates), then we may possess that data as part of the material you send us.
2. Uses and Purposes for Collection Information.
We may use your information for any or all of the following purposes, subject to any rights you may have under applicable law:
- Provide you the Services and administer our website and organization (including personalizing the website for you through cookies).
- Enhance, improve and optimize our offerings and website; make our websites more convenient; determine what you are interested in when you visit our website; and evaluate whether we should launch other offerings which we may inform you about.
- Send you newsletters, surveys, offers, and other promotions that may be of interest to you.
- Send you non-marketing email communications and other notifications via email, text or other methods (as you permit) that you have requested, including newsletters or updates.
- Compile technical or statistical information about our Services or use of our website.
- Answer your questions, respond to your requests, or investigate situations that you bring to our attention.
- Monitor your compliance with our terms and conditions.
- Ensure that our website remains secure and functional.
- Comply with applicable laws.
- Notify you of changes to this Privacy Notice and our handling of your information.
- Request your consent to use your information for new purposes.
- Anonymize or aggregate your information. Note that once information is anonymized, it will no longer identify you and is not subject to this Privacy Notice.
We will not, without your express consent, provide your information to third parties for marketing purposes.
3. Disclosure of Your Information to Others.
Your information may be accessible by our employees, directors, officers, professional advisers, agents or subcontractors providing us services consistent with the uses and purposes above. We do not currently have affiliates that would receive your information. We may disclose your information to others under the following circumstances:
- Use of service providers. Like many not-for-profits, November Project seeks to maximize its impact by keeping our costs down. We do this by sometimes outsourcing our online and information processing activities to third parties, which is less expensive than building our own systems. This may include building and running our website, or managing our data. When we do this, we may provide your data to, or collect it using, third-party service providers. These providers can only use your data to provide us the services we ask for.
- Publish information at your direction. If you provide us information to publish online or elsewhere, then we may display your information consistent with the purposes for which you gave it to us.
- Comply with law. November Project operates worldwide. Local laws may require us to disclose your information, in connection with ongoing or prospective legal proceedings, or to establish, exercise or defend our legal rights.
- Legal enforcement. We may disclose your information to the extent necessary to establish, exercise or defend our legal rights or important legal rights of others (including fraud prevention and reducing credit risk)
November Project does not sell or rent your data to third parties without your consent.
B. LINKS TO OUTSIDE WEBSITE AND SERVICES
If you are using our website and click on a link to any website that we do not control or operate, you will leave our website. At that point, we have no control over, and will not be responsible for, any privacy practices or data collection or use of any third party.
When donating to November Project, we may be collecting and using your information as described in Sections A and B. Furthermore, we may collect your name, email address, telephone number, and payment information when you make a contribution at a special event, over the phone, or by mailing in a check. From time to time, we may collect personal information from you in ways not described above.
In addition to the use and purpose of the collected information outlined in Section A and B, we may use your information in the following ways:
- To collect payment information, billing address, and other information necessary to process a donation or event registration.
- To comply with the law or in the good faith belief that such action is necessary to conform to the requirements of law or comply with legal process served on us.
- To protect against potential fraud. We may verify with third parties the information collected in the course of processing a gift, event registration, or other donation. If you use a credit or debit card, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us and that the card being used has not been reported lost or stolen.
We will not send you mailings or other promotions on behalf of other organizations.
E. WEBSITE ANALYTICS
We use internet analytics tools including Google Analytics to improve our understanding of how visitors interact with us online. We do not send your personal information to Google. Google places a ‘cookie’ file on your computer and uses that cookie to collect and aggregate data from you when you interact with our website. Google, which may have a profile of you from its other sources that we do not receive, provides us with an aggregated, anonymous report about our visitors, their demographics such as age or location, and their behavior while on the website. We may use the information to understand our user base, tailor our outreach efforts, and improve our website and offerings. Please click the following link for more information about Google’s collection and processing of your data as part of Google Analytics at the following link: http://www.google.com/policies/privacy/partners/.
Our website is designed and intended for use by adults and teenagers but not children under 13 years. We reserve our right to delete all personal information of children under 13 regardless of how it was obtained. A parent or legal guardian must be directly involved for any child to participate in our activities or use our Services.
If you are in Europe when you provide us your information, this section applies to that information. “Your information” and “personal information” in this section (Individuals in Europe) means: information relating to you that you provide to November Project while you are in a country that is in the European Union or European Economic Area (or both). The disclosures and rights in this section may not apply to information that does not meet that definition.
Transmission to the U.S.
November Project operates out of the United States even if certain activities organized by November Project occur in Europe. To provide you the Services you request, we require your consent to collect and store your information in the U.S. If you do not consent, or if you revoke your consent, laws may require us to delete your account and data permanently. We are obligated to inform you that in the U.S., you may have more difficulty exercising rights about your data, and there is no supervisory authority protecting your privacy in the U.S. You expressly Consent and Agree to our processing of your information in the United States. By giving us your information, you accept the risk that the U.S. may not offer guarantees ensuring a level of personal data protection equivalent to that of Europe.
Legitimate basis for information collection and processing.
We request consent for the collection and use of your personal information if you are in Europe. In addition, when you register, you agree to our terms and conditions and provide several waivers and authorizations. Those documents create agreements between you and us that we perform using your personal information. We may also use your information to exercise and enforce our rights under those agreements.
Compliance with laws.
We will keep your information for so long as you use the Services or otherwise desire to participate with November Project, or until you ask us to delete it. If we notice that you have not used or logged into any Services for at least 6 months, we may delete your information without any responsibility to you. However, we may retain your information as may be necessary to establish, exercise or defend our legal rights.
If you are a resident of a country in Europe (defined above), you have the rights, among others, to:
- Ask November Project to give you access to your information; permit you to object to our processing of your information; rectify (correct) or erase your information upon your request; restrict or object to our processing of your data for profiling, marketing or automated decision-making (if we do any of these); or obtain a portable version of your data, as required by applicable law in each case.
- Withdraw all or any consents for us to use your information, but note that applicable law may provide us another legitimate basis to continue processing your information.
- Lodge a complaint against us and our use of your information with the applicable supervisory authority, which is a regulatory body in the European Union member country where you live, work or where you believe we misused your information.
Please contact us at email@example.com to make requests or raise complaints with November Project regarding your information and this Privacy Notice.
We may update this Privacy Notice from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or other means as we deem appropriate or as we believe is required by law.
I. CONTACT INFORMATION
The entity issuing this Privacy Notice is November Project, Inc., a Massachusetts not-for-profit corporation based out of Boston, Massachusetts. You may contact us regarding this Privacy Notice and your rights hereunder at firstname.lastname@example.org, or by calling (617) 663-8860.
This Privacy Notice was last revised on July 18, 2021.