Privacy Policy

Effective May 19, 2020

IntroductionReturn 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.

This Privacy Policy (“Policy”) describes our policies and practices regarding the collection, use and disclosure of personal data you submit or we obtain in connection with your use of this Site.  This Privacy Policy applies to your use of this Site and by accessing or visiting the Site you are indicating your understanding that the collection, use, and sharing of your personal data is subject to this Policy. Please read this Policy carefully before using the Site or submitting personal data to us. Changes to our Policy apply to your use of the Site after the “effective date” listed above. 

Changes to this PolicyWe 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 CollectAs 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

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:

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.

Information On Your Use. We may collect information about and log your visits and use of the Site.  This includes, for example, when you view or click on embedded content.  We also use cookies and internet protocol (“IP”) addresses to identify you and log your use of the Site.  For more details see below.

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:

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.

Cookies and Similar Technology.   We may use technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons to recognize you when you return to the Site and to help us improve the quality of our service when you visit our Site. We also use cookies to tailor our products, services and advertising to suit your personal interests, estimate our audience size, track visits to and sales at our Site and, as applicable, to process your order, and track your status in our promotions, contests and awards

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:

How We Share Your DataIn 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.

We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data.

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.

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. 

Applicable law. This Policy is governed by the internal substantive laws of New York, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within New York. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

California Residents.  If you are a California resident, please read the following:

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

320 7th Avenue, #127

Brooklyn, NY 11215