Revised AUGUST 9, 2018
What Is Personal Information?
The term “Personal Information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, or credit card number), or information about that individual that is directly linked to personally identifiable information. You may provide Personal Information directly to Namchak through interacting with the Site, participating in surveys, registering for eCourses, joining and/or forming Learning Circles, and participating in events such as sweepstakes, online chats and other interactive media.
Personal Information does not include “aggregate” information, which is data we collect about the use of the Site or about a group or category of services or users, from which individual identities or other Personal Information has been removed. This Policy in no way restricts or limits our collection and use of aggregate information.
What Personal Information Do We Collect?
We collect information about you in various ways when you use our Site. We collect certain information you voluntarily provide to us, such as when you join or form a Learning Circle, participate in group calls, send us an email, provide or request information, participate in surveys, register for sweepstakes or contests or post blog comments or other content on the Site. Such information may include Personal Information, such as your name, email address, and phone number.
When you visit our Site, some information is also automatically collected. For example, we log information such as your Internet Protocol (IP) address, operating system, browser type, address of a referring website, and your activity on the Site. We treat this information as Personal Information if we combine it with, or link it to, any of the identifying information mentioned above. Otherwise, it is used only in the aggregate.
We may also automatically collect certain information through the use of “cookies” or web beacons. Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us improve our Site and your experience. If we link cookies to any personally identifying information, we will treat this information as Personal Information. We do not use “cookies” to obtain Personal Information about any of our visitors. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. Most Internet browsers allow you to set them to warn you before a cookie is stored or block cookies altogether. However, if you choose to remove or reject cookies, this could affect certain features on our Site. Web beacons are small, invisible graphic images that may be used on the Site or in emails relating to the Site to collect certain information and monitor user activity on the Site.
We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Site through a Third-Party application, such as an App Store or social network site (“SNS”), we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business and Services.
How Do We Use the Personal Information We Collect?
We use Personal Information collected through our Site for the purposes described in this Policy or elsewhere on the Site. For example, we may use Personal Information we collect:
- to respond to your requests, comments, and questions;
- to notify you about Learning Circles and other group activities;
- to send you confirmations, updates, security alerts, and support and administrative messages;
- to send you news and other information about the communities and Namchak events and to provide you with other information about ways to stay involved;
- to inform you about challenges, events, promotions, services or other news and information about Namchak that we think will be of interest to you;
- to analyze trends and personalize and improve the Site and the user experience on the Site;
- to notify you about important changes to our Site; and
- for any other purpose for which the Personal Information was collected.
We may also collect Personal Information from you about a third party (e.g., the Site might allow you to send an email or message to a friend, in which case we will need that person’s name and email address). Please note that we use such information only for the specified purpose (e.g., to deliver the email message) and we will not contact the third party again by email unless and until the third party contacts us. We may also enhance your Personal Information by linking it to data obtained from third parties, such as non-personally identifiable information (e.g., demographic and geographic characteristics) as well as other publicly available data such as census information. Such enhanced information allows us to provide our users with a more customized experience.
We may use Personal Information to provide you with materials about offers, products, and services that may be of interest, including new content or services. We may provide you with these materials by email, as permitted by applicable law. Such uses include, to tailor content, advertisements, and offers; to notify you about offers, products, and services that may be of interest to you; to provide services to you; for other purposes disclosed at the time that Individuals provide Personal Information; or otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes.
We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products and services. From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails and newsletters from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual.
We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Namchak and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
We may offer various tools and functionalities such as Learning Circles. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to join a Learning Circle. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request but will not be collected or otherwise used by us or any other Third Parties for any other purpose.
We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
We, and third-party service providers employed by us may store and process Personal Information in the United States and other countries.
Google Analytics Cookies
We use Google Analytics to collect information about visitor behavior on the Site. The Google Analytics Demographics and Interest Reporting feature allows us to identify trends in the usage of the Site which may be published in reports for internal use and to develop the Site and content around our visitors’ interests. We use Remarketing with Google Analytics to advertise online and make ads more relevant.
Demographics and Interests data comes from the third-party DoubleClick cookie for web traffic. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. We therefore do not use this tool to collect or store your Personal Information, so this information cannot be used to identify who you are.
We have also turned on Remarketing with Google Analytics. Remarketing cookies will be used by third parties (including Google) to show our ads on websites other than our own. We use Google Analytics’ Remarketing cookies to serve more relevant ads on third-party websites based on your past visits to our website or other websites. Google operates the DoubleClick online ad serving product, providing advertisers, web publishers and direct marketers with the tools needed to plan, execute, and analyze marketing programs with greater ease and efficiency. Note: Cookies placed by Google for behavioral advertising, including the opt-out cookie, will appear as DoubleClick cookies.
Opt-out of Google Analytics
Using the Ads Settings (www.google.ca/settings/ads), you can opt-out of both Google Analytics for Demographics and Interest Reporting and Remarketing with Google Analytics. In addition, you can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. Google is a Network Advertising Initiative (NAI) member, which is an organization committed to transparency and choice. The NAI opt-out tool was developed in conjunction with the Digital Advertising Alliance (DAA) for the express purpose of allowing consumers to “opt out” of the Interest-Based Advertising delivered by members on Web pages using cookies.
What Personal Information Do We Share with Third Parties?
We will not share the Personal Information we collect from you through this Site with third parties, except as described in this Policy or on the Site.
We may also share Personal Information with our vendors, consultants, and other service providers (“Service Providers”) who are engaged by or working with us in connection with the operation of the Site and who need access to such information to carry out their work for us. In some cases, the Service Provider may be directly collecting information from you. We may also share Personal Information with other third parties when you give us your consent. We are not responsible for the actions of Service Providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties, and we encourage you to become familiar with their privacy practices before disclosing information directly to any such parties. Nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent.
In the course of doing business, we may employ other companies to perform a variety of functions on our behalf. For example, at times we may retain third parties to analyze, update and correct data we collect on our web sites, including Personal Information, to help us improve our products, our database and our website. In addition, we may share Personal Information with agents, suppliers, fulfillment houses and other third parties to allow delivery of awards, information, products or services. These suppliers and other third parties may have access to your Personal Information if it is needed to perform their functions for us, but they are not authorized by us to use your Personal Information in any way other than the intended use
You agree that we may use Personal Information about you to improve our marketing and promotional efforts, to analyze site usage, improve our content and product offerings, and customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.
We cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as: intellectual property rights, fraud and other rights. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, state, telephone number, email address and User ID history without a subpoena. Without limiting the above, in an effort to respect your privacy, we will not otherwise disclose your Personal Information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to: prevent imminent physical harm or financial loss; or report suspected illegal activity. Further, we can (and you authorize us to) disclose your name, street address, city, state, zip code, country, phone number, email, and company name to proper authorities under confidentiality agreement, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity.
Links to Other Websites
What Steps Do We Take to Protect Your Information Online?
Namchak takes reasonable measures to protect your Personal Information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission that can be guaranteed against any interception or other type of misuse. Notwithstanding the foregoing, we cannot guarantee the security of any information you disclose online, and you do so at your own risk.
To protect the confidentiality of Personal Information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our Site by any person using your password. Please advise us immediately if you believe your password has been misused. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
What Choices Do You Have Regarding the Use of Your Information?
You may “opt out” of receiving promotional emails from Namchak by following the instructions in those emails. You may also opt out of such emails by emailing us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
Important Note Regarding Cross-Border Data Transfers
The laws and regulations in different countries impose different requirements on the Internet and data protection. We are located in the United States, as are the servers that make our site available worldwide. All matters relating to our sites are governed by the laws of the State of Montana and the United States. If you are located outside of the United States, please note that any information you provide will be transferred to the United States, which may not have privacy laws similar to those in your own country, and that by submitting the information you authorize this transfer. All Personal Information collected by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you explicitly consent to the storage of your Personal Information in these locations.
From time to time, portions of our site may allow you to post information which other visitors to the site will be able to access (such as on a “forum”). In the event that you choose to post information in this context, it becomes generally available to the public, and we have no ability to control or limit its use by visitors to our sites. Therefore, we encourage you not to post any information you consider private or sensitive on our site.
Important Note to Children under the ages of 13 and 18
If you are between ages 13 and 18, before providing your name, address, email address or any other Personal Information to anyone on the Internet, be sure to ask your parents’ or legal guardian’s permission.
Our Site is not intended for and we do not knowingly collect information from children under the age of 13. If you believe that your child has registered with our Site or that we have collected information from your child, please contact us immediately so that we can remove that information from our database.
Rights of Access, Rectification, Erasure, And Restriction
Although we make good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Visiting our Site from the European Economic Area (EEA)
The Legal Basis for Using European Personal Information
When we collect information about you through our Site, the legal basis on which we process your Personal Information is fulfillment of an agreement between us, namely, to provide you with products and services, to purchase or review products, and other information marketing our products. We may also send certain communications because we have a legitimate business interest in making such marketing communications to you. When we use your Personal Information outside of what is strictly necessary for that transaction, we are doing so toward our legitimate interest of informing you of related products and promotions.
To the extent that we transfer Personal Information from the EEA to a jurisdiction outside the EEA that has not been adduced by the European Commission as providing adequate data protections (such as the US), the basis for such transfer is the necessity of providing you with information, products, or services you have requested.
Rights for EEA Residents
In addition, if you are a resident of the EEA, you have the right to:
Find out if we use your Personal Information, to access your Personal Information, and receive copies of your Personal Information;
Withdraw any express consent that you have provided to the processing of your Personal Information at any time without penalty;
Access your Personal Information and have it corrected or amended if it is inaccurate or incomplete;
Obtain a transferable copy of some of your Personal Information which can be transferred to another provider when the Personal Information was processed based on your consent.
If you believe your Personal Information is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Information, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
These provisions are intended to comply with the EU General Data Protection Regulation requirements.
Request your Personal Information be deleted or restricted under certain circumstances. For example, if we are using your Personal Information on the basis of your consent and have no other legal basis to use such, you may request your Personal Information be deleted when you withdraw your consent.
If you wish to exercise any of these rights or raise a complaint on how we have handled your Personal Information, please contact us at email@example.com.
California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their Personal Information for direct marketing purposes during the preceding calendar year and the categories of Personal Information shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email at firstname.lastname@example.org with “California Privacy Rights” in the subject line.
Manage Your Personal Information; Unsubscribe
We offer you the ability to automatically review and change the information you submit to us by logging into the Site and entering in the new information yourself. Generally, we will not modify your Personal Information based on your request because it is very difficult to authenticate your account manually. You can change your User ID, email address, contact information and user preferences by accessing the preferences and setup section of the Site. You must promptly update your Personal Information if it changes or is inaccurate. Once posted, you may not be able to change or remove any public postings made on the Site including our chat rooms or other message areas.
Upon your request, we will deactivate your account and all associated information from our active databases. Such information will be deactivated as soon as reasonably possible based on your account activity and in accordance with our deactivation policy and applicable law.
If you have any questions about this Policy, please contact us at:
400 W Broadway, Ste 101-233
Missoula, MT 59802
Phone # 406.541.3000