Effective May 19, 2020
Introduction. Return On Inclusion™/ Griffin Group LLC and its affiliates and related entities (collectively, “Company,” “us,” or “we”) is/are committed to protecting the privacy of certain data that is collected from you and that you submit when you access this website or websites, apps, or other online media under our operation and control (collectively, the “Site”). The nature of our business requires that we gather and maintain information that is of a personal nature that you wish to keep protected.
Changes to this Policy. We reserve the right to change this Policy at any time. In the event we make material change(s) to the Policy, we will provide notice through the Site. Changes will be effective immediately upon posting to the Site and will apply to your use of the Site after the “effective date” listed above. You understand and agree that your continued use of the Site after the effective date, means that the collection, use, and sharing of your personal data is subject to the updated Policy.
Except to the extent we obtain your consent or as permitted or required by applicable law, we will handle your personal data collected through the Site in accordance with the terms of the Policy in effect at the time of such collection.
Information We Collect. As you are probably aware, we may collect information from a variety of sources to operate the Sites, carry out our business, comply with law and other purposes described herein.
Personal Data You Provide
Creating a Return On Inclusion™ Account
School or Affiliation
Job title, years of experience
Uploading documents or completing forms. If you upload documents (e.g. your CV or resume) or complete forms on the Site (e.g. compliments for our goods or services, application for employment), we may collect the personal data contained in those documents/forms.
You provide data when you order or receive products or services from us.
Ordering/Receiving Products, Information or Services. If you order or receive products or services from us we may collect the following:
Marketing and communication preferences
And other types of personal data that you choose to provide to us or that we may obtain about you
You do not have to provide the above personal data to access or use the other sections of the Site.
Personal Data From Third Parties. We may collect personal data about you from third parties such as through your social media services consistent with your settings on such services, and from other third-party sources that are lawfully entitled to share your data with us. We use and share this personal data (and may add it to the other information we have on file for you) for the purposes described in this Policy.
Statistical Data. To monitor utilization of the Site and continuously improve its quality, we may compile statistical information concerning the usage of the Site using analytics services, such as those provide by Google Analytics. Examples of this information would include: the number of visitors to the Site, or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Site. The analytics services may transfer this information to third parties in case of a legal obligation or if a third party processes data on behalf of that service. To compile this information, we may collect and store:
Your IP address
Your operating system version
Your browser version
The pages you visit within the Site
The length of time you spend on pages within the Site
The site from which you linked to ours
Search terms you used in search engines which resulted in you linking to the Site, etc.
While all of this information can be associated with the IP address your computer had while you visited the Site, it will not be associated with you as an individual, or associated with any other personal data you may submit through the Site, or that we may store about you for any other purposes.
You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. If you do so, our Site may not function correctly. Please refer to the Help feature of your browser for information on disabling cookies.
IMPORTANT: By using the Site, you consent to the processing of any personal data for the analytics purposes and functions described above.
How We Use Your Personal Data. In general, we will use the personal data we collect about you only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy. For example, we may use your data:
To respond to your requests for information relating to our products and services.
To communicate with you. We will send you messages about the availability of our Site, security, or other service-related issues. You may change your communication at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.
In connection with your employment or prospective employment. If you submit personal data through the Site in connection with an application for employment or as part of the onboarding process, we will use that data in connection with the employment or prospective employment relationship.
For our research and development efforts. We use data, including public feedback, to conduct research and for the development of the Site and the services and products we provide to you.
For other everyday business purposes. By way of example, product development, contract management, IT and website administration, fulfillment, analytics, fraud prevention, corporate governance, reporting and legal compliance.
To provide you with the products and/or services you have ordered or requested. This might include whitepapers, books, digital materials.
To market our products or services that we think may be of interest to you. For example, to send you newsletters and promotions using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means.
To ensure your personal data is accurate and to personalize our products and services. For example, we may aggregate your personal data with data from third-party sources for purposes of keeping information up to date. We also rely on information from third parties in order to provide better, more personalized service. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Policy.
How We Share Your Data. In general, we will not disclose your personal data collected through the Site except with your consent and as described in this Policy. We may disclosure your data for the same reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non-affiliated entities, as we deem necessary to carry out those purposes.
Third Party Vendors. We may need to use or disclose this personal data with our third-party vendors:
With your consent or as you direct;
To manage the Site;
To provide you with products, services, or offers;
To engage in marketing activities;
To enhance our services by, among other methods, obtaining assistance with providing more personalized services to you through analytics and other technologies;
To protect our interests and legal rights, such as through responding to subpoenas and defending litigation;
To protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities; and
To review and process applications for employment.
We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data.
Legal Process, Security, Defense, Protection. It is possible that we will need to disclose personal data about you if required by law, subpoena, or other legal process. Additionally, we may disclose personal data about you if we have a good faith belief that disclosure is reasonably necessary to:
demonstrate our relationship with you;
investigate, prevent, or take action regarding suspected or actual illegal activities or to assist law enforcement agencies;
protect the security or integrity of the Site;
investigate and defend ourselves against any third-party allegations or claims; or
protect the rights and safety of others.
Change in Control or Sale. We can share, sell, assign, or license your personal data in connection with certain business transactions, such as a sale, acquisitions, merger, or change in control, or in preparation for any of these events. In such cases, we will take appropriate steps under the circumstances and to the extent possible to ensure that the recipient agrees to provide privacy protections substantially similar to those established by this Policy. Any entity that acquires all or substantially all of the Company’s assets will have the right to continue using your data consistent with this Policy or as otherwise agreed to by you.
In no case will we share, sell or license your data to third parties, except as set forth above or as required or permitted by law.
Social Media Plugins. This Site uses social media plugins (e.g. Facebook and LinkedIn) to enable you to easily share information with others. When you visit our Site, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Site. If you are logged into the social media website (e.g. Facebook, Twitter) while browsing our Site, the social plugins allow that social media website to share data about your activities on our Site with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. We do not control any of the content form the social media plugins. For more information about social plugins from other media websites you should refer to those sites’ privacy and data/information sharing statements/policies.
Safeguarding of Personal Data. No system for safeguarding personal or other data is 100% secure and even though we have taken steps to protect your personal information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal data. However, we take a number of steps to safeguard the security of personal data obtained through the Site. For example, we have implemented a security program that contains administrative, technical and physical controls that are designed to reasonably safeguard your personal data from unlawful use, unauthorized access or disclosure. Additionally, we use Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our Site. However, again, there is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, physical, or technical safeguards.
Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Links to Third Parties’ Sites. We may provide links to websites or resources outside of our Site for your informational purposes only. You acknowledge and agree we are not responsible for the availability of such sites or resources, and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through or provided by such sites or resources. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of any of your personal data that you provide or may be collected by such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.
Information of Children. The Site is not directed to children as the products and services on this Site are intended for persons 18 years of age and older. The Company does not knowingly collect, use or disclose any personal data from children. If you are concerned about your child’s use of the Site, you may use web-filtering technology to supervise or limit access to the Site.
California Residents. If you are a California resident, please read the following:
California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by certain members of the Company to third parties for the third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). You may submit your request using the contact information at the end of this Policy.
If you are under the age of 18, and a registered user of any site where this policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information at the end of this Policy. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Your Choices Regarding Your Personal Data. You can always limit the personal data you provide to us, but if you choose not to provide certain requested information, you may be unable to access some of the services, offers, and content on the Site. You can also limit the communications that we may send you by following a simple opt-out or unsubscribe process. Simply follow the instructions in our newsletter/advertisement/promotional emails to opt-out of receiving, or unsubscribe from, future marketing communications.
Please note that even if you opt-out of promotional communications, we may still need to contact you with important transactional data about your account. For example, even if you opt-out of promotional communications, we will still send you a notification of changes to, expiration of, or discontinuation of a program you are enrolled in.
How to Contact Us. If you have any questions regarding this Policy, your privacy, or our policies in the event of a compromise of your personal data, you may contact us at:
Return On Inclusion™/Griffin Group LLC
115 S. Oxford Street
Brooklyn, NY 11217