Effective 20 April 2021
Northshire Media Inc., (“NMI”, “us”, “we”, the “Company”) owner and operator of 50mmFramework.com (“Website”) recognizes the importance of protecting the privacy of any personal information we collect. We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it and how it is used.
2. Information We Collect
Information you give us
You choose to give us certain information when using our services. This includes:
When you create an account, you provide us with at least your login credentials, as well as some other basic details necessary for the service to work, such as your name, and email address.
When you complete your profile, you can share additional information with us, such as uploading a profile picture for your account.
When you subscribe to a paid service or make a purchase directly from us, you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions, and testimonials.
When you choose to participate in our promotions, events, or contests, we collect the information that you use to register or enter.
If you contact us through 50mmFramework.com (the “Website”), we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people, we collect the information about others that you give us in order to complete your request.
Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, including:
Other Users: Other users may provide information about you as they use our services. For instance, we may collect information from faculty members about students enrolled in our memberships/courses.
Other Service Providers: We may receive information about you from third parties that provide us with services related to our business. For example, our partners may provide us with certain metrics related to your use of our services, including details regarding your engagement with our courses, time you spend on different areas of our website, customer support interactions, or details about the success of an NTMI advertising campaign.
Information collected when you use our services
When you use our services, we collect information about which features you use, how you use them, and the devices you use to access our services. See below for more details:
Usage Information: We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you use, searches, clicks, and pages which have been shown to you, referring web page address, advertising that you click on, time spent live chatting).
Device information: We collect information from and about the device(s) you use to access our services, including:
hardware and software information such as IP address, device ID and type, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); and
information on your wireless and mobile network connection, like your service provider and signal strength.
3. Cookies and Other Similar Data Collection Technologies
4. How We Use Information
We use your information (whether collected directly from you or from our other users or service providers) in the following ways:
To administer your account and provide our services to you
– Create and manage your account
– Provide you with customer support and respond to your requests
– Complete your transactions
– Process refunds
– Communicate with you about our services, including order management and billing
To ensure a consistent experience across your devices
Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version, and similar data about your devices to help identify and link them.
To provide new NMI services to you
– Register you for new NMI features
– Administer your account on these new features
To serve you relevant offers and ads
– Administer sweepstakes, contests, discounts, or other offers
– Develop, display and track content and advertising tailored to your interests on our services and other sites
– Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
To improve our services and develop new ones
– Administer focus groups and surveys
– Conduct research and analysis of users’ behavior to improve our services and content
– Develop new features and services
To prevent, detect and fight fraud or other illegal or unauthorized activities
– Address ongoing or alleged misbehavior on and off-platform
– Perform data analysis to better understand and design countermeasures against these activities
– Retain data related to fraudulent activities to prevent recurrences
To ensure legal compliance
– Comply with legal requirements
– Assist law enforcement
– Enforce or exercise our rights
To process your information as described above, we rely on the following legal bases:
– Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us.
– Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, to suggest offers we think might interest you, and to process information for administrative, fraud detection, and other legal purposes.
5. How We Share Information
With other users
You share information with other users when you voluntarily disclose information on the Website (for example, in a product review or testimonial). Please be careful with your information and make sure that the content you share is information that you are comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.
With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, and security operations.
We share your information with other service providers for them to assist us in processing your information, as service providers, upon our instructions, and on our behalf. Assistance provided by other companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing, and targeted advertising, finance and accounting assistance, better understanding how our service is used and users’ behavior to improve our service, securing our data and systems and fighting against spam, abuse, fraud, infringement, and other wrongdoings.
We may also share information with other companies for legitimate business purposes such as corporate audit, analysis, and consolidated reporting as well as compliance with applicable laws.
We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.
When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources.
6. Cross-Border Data Transfers
Sharing of your personal information sometimes involves cross-border data transfers outside of Canada. If your personal information is transferred to another jurisdiction, then it may be accessible to the law enforcement and national security authorities of that jurisdiction.
7. Your Rights
We want you to be aware of your privacy rights. Here are a few key points to remember:
Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability, or variations of those terms). You can request a copy of your personal information by contacting our Privacy Officer.
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and you want to request its rectification, deletion, or object to its processing, you can contact our Privacy Officer.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can provide you with a copy of your personal information or rectify your personal information.
We may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user.
If you wish to receive information relating to another user, the other user will have to provide us with their written consent before the information is released. Notwithstanding the foregoing, we reserve the right, in our sole discretion, to reject any request for information about another user.
We may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.
You may delete your account at any time, from which time we will not collect any additional information about you.
In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work, or where we are established.
8. How We Protect Your Information
We implement physical, organizational, and technological measures to protect your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify our Privacy Officer immediately.
9. How Long We Retain Your Information
We keep your personal information for as long as we need it to provide the services and as permitted or required by applicable law. We delete or anonymize your information upon deletion of your account, unless:
1. we must keep it to comply with applicable law;
2. we must keep it to evidence our compliance with applicable law;
3. there is an outstanding issue, claim, or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.
10. California Privacy Rights
For users who are California residents, the data we may collect falls within the following categories of “personal information,” as defined by the California Consumer Privacy Act (CCPA):
1. Identifiers, such as name and location;
2. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
3. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, and marital status;
4. Commercial information, such as transaction information and purchase history;
5. Internet or network activity information, such as browsing history and interactions with our websites;
6. Geolocation data, such as mobile device location;
7. Audio, electronic, visual, and similar information, such as photos;
8. Professional or employment-related information, such as work history and prior employer;
9. Non-public education information; and
10. Inferences are drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
1. You have the right to request that we disclose certain information to you and explain how we have collected, used, and shared your personal information over the past 12 months.
2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.
3. You have a right to request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year.
11. Children’s Privacy
Our services are restricted to users who are 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please report it through the Website.
Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
13. How to Contact Us