Last Revised: May 2018

Your Privacy on One North’s Website

One North Interactive LLC (“One North”, "we", “us”, “our”) is committed to protecting your information when you visit the One North Interactive site at www.onenorth.com (“One North Website”). This privacy policy is based on the fundamental goal of providing you with quality information about your rights and protecting your personal privacy (“Privacy Policy”). 

By accessing or using the One North Website, you signify that you acknowledge, accept, and agree with all the terms of this Privacy Policy, so do not use or access this site if you disagree with any part of this Privacy Policy. You should check this page from time to time to ensure that you continue to agree with the terms of this policy. 

It is important that you read this Privacy Policy carefully and other privacy notices that we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.
 

1. Information We Collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  1. Identity Data includes first name, last name, username, or similar identifiers.

  2. Contact Data includes billing or shipping address, email address, or telephone number.

  3. Transaction Data includes details about payments to and from you and other details of services that we have provided to you.

  4. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the One North Website.

  5. Profile Data includes your username and password, subscriptions made by you, your interests, preferences, or feedback responses.

  6. Usage Data includes information about how you use the One North Website and services.

  7. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.


We also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific One North Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

Providing Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.

2. Methods We May Use to Collect Data About You

We use different methods to collect data from and about you including through:

  1. Direct Interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise; this includes personal data you provide when:

    1. fulfilling your request to register for an event you signed up for on the One North Website.

    2. fulfilling your request(s) for access to white papers, event recordings, and/or newsletter subscriptions.

    3. navigating the One North Website. Offering a better browsing experience by optimizing the layout and display of content for the device you are using to view the One North Website.

    4. submitting survey responses to us

    5. we contact you for One North’s marketing purposes, with your consent.

  2. Automatically Collected Information. The One North Website collects standard internet log information, listed below. We use this information for system administration, to filter traffic, and to report on statistics for things like which domains are referring to the One North Website and top browsers and display details for optimizing the use of the One North Website for most users. All information listed below does not reveal your specific identity nor does it directly relate to an individual. The data collected automatically from you is not distributed to third parties.

    1. Internet domain of the referring website, website page visits and actions on the website, and IP address of the computer you are using. We collect GeoIP information based on the IP address.

    2. type of browser and operating system, time of access and date stamp

    3. information about the device you are using to access the One North Website

    4. we track return visits to One North Website using cookies, which are text files containing small amounts of information that are downloaded to your browsing device. Please see the Cookie section for more details.

  3. Third Parties or Publicly Available Sources. We may receive personal data about you from various third parties as set out below:

    1. Technical Data from the following parties:

      1. analytics providers such as Google based outside the EU

3. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. When you allow us to collect your personal data by expressly consenting to receive direct marketing communications via email (you have the right to withdraw consent to marketing at any time by contacting us).

  2. Where you allow us to process your personal data on the basis of that consent (you have the right to withdraw consent to marketing at any time by contacting us).

  3. Where we need to perform the contract we are about to enter into or have entered into with you.

  4. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  5. Where we need to comply with a legal or regulatory obligation.

Purposes for Which We Will Use Your Personal Data
We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate. (‘legitimate interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of Data Lawful Basis for Processing

To register you as a new customer

  1. Identity

  2. Contact

Performance of a contract with you

To register you for a new event, conference, or webinar

  1. Identity

  2. Contact

Necessary for our legitimate interests (to keep our records updated)

To provide our services (fulfilling your request(s) for access to white papers, event recordings, and/or newsletter subscriptions)

  1. Identity

  2. Contact

  3. Profile

  4. Marketing and Communications

  1. Performance of a contract with you

  2. Necessary to comply with a legal obligation

  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

To manage our relationship with you, which will include:

  1. Notifying you about changes to our terms or privacy policy

  2. Asking you to leave a testimonial or complete a survey

  3. Sending you marketing communications to notify you about our new initiatives or services

  1. Identity

  2. Contact

  3. Profile

  4. Marketing and Communications

  1. Performance of a contract with you

  2. Necessary to comply with a legal obligation

  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

  4. Necessary for our legitimate interests (to develop our services and grow our business)

To administer and protect our business and the One North Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity

  2. Contact

  3. Technical

  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

  2. Necessary to comply with a legal obligation

To use data analytics to improve the One North Website, services, marketing, customer relationships and experiences

  1. Technical

  2. Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep the One North Website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile

Necessary for our legitimate interests (to develop our services and grow our business)


Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

  1. Unsubscribing: You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.

  2. Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the One North Website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy below.

Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose or legally necessary. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  1. Service providers based in the United States that provide IT and system administration services.

  2. Business partners including caterers, hotels, and others to assist us in organizing our conferences and networking events.

  3. Professional advisers, including lawyers, bankers, auditors, and insurers, based in the United States that provide consultancy, banking, legal, insurance and accounting services.

  4. Regulators and other authorities based in the United States and European Union that require reporting of processing activities in certain circumstances.

  5. Market researchers

  6. Fraud prevention agencies

  7. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. Data Security and Integrity

One North has implemented technology and security that follows reasonable industry standards to protect and support the secure use, processing, storage and transmission of your personal data. All of One North’s security policies and procedures are designed to meet the three main objectives of Confidentiality, Integrity and Availability while following our guiding principles, which are as follows:

  • Share Accountability: One North’s culture of security ensures everyone is responsible for security.
  • Limit Access: The right people have access to the right information, at the right time, and no more than that.
  • Balance Goals: We ensure the business goals we establish complement and strengthen our security goals.
  • Be Proactive: We take proactive steps to ensure our efforts are designed to prevent unauthorized access to data.

One North is committed to protecting the privacy of your data from unauthorized access, disclosure, alteration, or destruction. We use reasonable organizational, technical and administrative measures to protect personal data (email address, telephone number) under our control.

How Long Will You Use My Personal Data For?
We will retain users’ personal data for the timeframe necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by lawful or regulatory purposes.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

6. Your Rights, Choices and Access

Users have the option to discontinue receiving marketing emails from One North at any time. Users can opt out of our marketing emails by clicking the “unsubscribe” link at the bottom of our marketing communication emails.

Also, all unsubscribe requests can be made by contacting us.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  2. Request correction of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be outlined for you, if applicable, at the time of your request.

  4. Object to processing of your personal data. This enables you to ask us to delete or remove personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which overrides your rights and freedoms.

  5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

  6. Request the transfer of your personal data to you or to a third party. This enables you to ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

  7. Withdraw consent at any time, where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

When submitting a personal data request, please state clearly what changes or limitations are needed for your use of personal data. We treat information access requests in accordance with the applicable legal requirements before processing the request, which includes verification of your identity.

7. Data Transfers

One North is headquartered in the United States, and we have operations, entities, and service providers in the United States. Many of our external third parties are based outside the European Economic Area (“EEA”), so their processing of your personal data will involve a transfer of data outside the EEA.

We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Third-Party Websites

The One North Website may link to other third-party sites that are not controlled by One North and are not covered by this policy. We do not warrant or guarantee the type of information third parties collect nor how they do so. Users should be fully aware of the third party’s policies and documentations.

9. California Privacy Rights

Under California Civil Code Section 1798.83 (known as the “Shine the Light” law), One North members and customers who are residents of California may request certain information about our disclosure of personal data and information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us with “Request for California Privacy Information” on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response.

10. Children

The One North Website is not intended for children under eighteen (18) years of age. One North does not market any services to children under eighteen (18) years of age or knowingly collect any information from children under eighteen (18) years of age. If you believe that we might have any unauthorized information from or about a child under the age of 18, please contact us as soon as possible.

11. Updates to Privacy Policy

One North may modify this Privacy Policy at any time, at our discretion. When changes are made to this Privacy Policy, we will update the revision date at the top of this page. We encourage you to review this Privacy Policy from time to time, so you understand how we are protecting your data on the One North Website.

12. Contact Information

One North Interactive, LLC
Attn: Privacy Policy Request
222 N. LaSalle Street, Suite 1500
Chicago, IL 60601

(312) 469-1740

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us by emailing privacy@onenorth.com.