Privacy Policy

PRIVACY POLICY

 

LAST REVISION: OCTOBER 05, 2020

 

Northeast Generals is committed to respecting the privacy rights of all of the visitors and users of the websites and apps operated by or on behalf of Northeast Generals, including any websites on or apps in which this Privacy Policy appears and all northeastgenerals.com URLs (collectively, the “Sites”). This Privacy Policy sets forth what personal and usage information Northeast Generals collects through the Sites, as well as how that information is used, maintained, and in some cases, shared with third parties. This Privacy Policy also sets forth how to contact Northeast Generals if you have any questions about the privacy of your information.

 

Please read this Privacy Policy carefully to understand Northeast Generals’ practices regarding your information and how Northeast Generals will treat it. By visiting or using any of the Sites, you acknowledge that you are expressly accepting and consenting to the practices and policies outlined in this Privacy Policy.

 

This Privacy Policy applies only to information that you provide to Northeast Generals while visiting or using the Sites, and does not apply to any information that Northeast Generals has received, obtained or may obtain through third parties, offline or through other means, or any third parties that may obtain information about you from the Sites. If you enter or choose to leave Northeast Generals’ Sites via links to other non-Northeast Generals websites or apps, your visits and actions on those websites and apps are not covered by this Privacy Policy.

 

We use TrueDepth API technologies (ARKit, with automatic estimation of the real-world directional lighting environment) to create AR effects within the App. The only use of this information is to provide valuable user features. None of the information collected by the TrueDepth API ever leaves the user’s device. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API. For more information about TrueDepth API technologies, you may visit https://support.apple.com/en-us/HT208108.

 

Does Northeast Generals Collect Any Information About Users Under Age 13?

 

Northeast Generals does not knowingly solicit or collect information from anyone under the age of 13, unless explicitly stated on a Site, and unless stated therein, all the Sites are directed at persons 13 years of age or older. If you are the parent or guardian of a child under the age of 13, or the legal age of contract majority, and have authorized your child to use your computer, Northeast Generals urges you to instruct your child never to give out his or her real name, address, phone number, email address or other personally identifying information while on the Sites. There are no computer applications on the Sites which allow for the determination of your

age. If Northeast Generals discover that personal information of a child under 13 has been collected without parental or guardian consent, Northeast Generals will take reasonable steps to delete this information. All information volunteered to Northeast Generals will be treated the same as information given by an adult. Northeast Generals recommends that the Internet browsing behavior of any child should be carefully supervised by a responsible adult at all times.

 

Does Northeast Generals Collect Any Information About Users Age 13 and Older?

 

General Information Collected

 

To enhance the content contained on or in the Sites, Northeast Generals may gather and store certain general information about your visit. “General Information” is information about you or your activities through which you cannot be identified. This information may include some or all of the following items:

 

The Internet Protocol (“IP”) address of your Internet Service Provider (“ISP”) and/or your computer, if it has its own static IP address. The domain name may also be collected. Your IP location information may be used during your visit to the Sites to serve you location specific information or advertisements for goods or services available in your specific location, however, such information will not be collected or maintained by Northeast Generals except in aggregate or generic form.

 

The date, time, length of stay and specific Northeast Generals web pages, images, videos, documents or forms accessed by you at such Sites, including videos or content you watch or interact with.

 

Whether you are viewing any of the Sites for the first time or are a return visitor.

 

The Uniform Resource Locator (“URL”) of the website or advertisement that referred you to any of the Sites.

 

The search engine that referred you and any search strings or phrases entered into the search engine to find any of the Sites.

 

Demographic information concerning your country of origin and language(s) used.

 

The type and version of the Internet browser used to visit any of the Sites, the operating system on your computer or device and information regarding errors when viewing any of the Sites.

 

Pages you viewed or searched for, page response times, download errors, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

 

Northeast Generals collects this General Information and may use it to generate generic or aggregate statistics about visitors to and users of the Sites. In situations where it is possible to do so, General Information may be linked to Personal Information.

 

Personal Information Collected

 

“Personal Information” is information through which you can be identified. Providing your Personal Information to Northeast Generals is your choice. Northeast Generals maintains one or more databases to store your Personal Information and may keep such information indefinitely.

 

To participate in the various services provided on the Sites, Northeast Generals ask for Personal Information, which may include your full name and email address. Northeast Generals also may collect other information such as city and/or state, and country, which Northeast Generals considers Personal Information only if combined with any of the items of Personal Information listed in the first sentence of this Section. Northeast Generals explains below how Northeast Generals will use this information.

 

Social Media

 

The Sites may include social media features, including links to share, post or link Northeast Generals’ content through your accounts with third party social media services. If you choose to interact with social media features on or from the Sites, or if you are logged in to your social media accounts while using the Sites, social media services may collect information about your use of the Sites. Information collected by third party social media services is governed by the privacy policies of those third parties, not Northeast Generals.

 

Northeast Generals may collect your social media username or ID, social media plug-in information, and URL clickstream to, through and from the Sites (including date and time). Information collected by social media sites may include names, titles or descriptions of videos or content viewed through your use of the Sites. Your use of the Sites and any third party social media services constitutes your agreement and consent to the collection and use of information about the videos and content you view through the Sites.

 

Third Party Advertising

 

Northeast Generals may collect information about your activity on the Sites with third parties for ad distribution and ad optimization (defined as the tailoring, targeting [i.e., behavioral, contextual], retargeting, analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect information for such purposes. Pixel tags enable Northeast Generals and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, Northeast Generals may receive information from advertisers and/or their

service providers such as advertising identifiers, IP addresses, and post-conversion data. These third parties may collect any of the types of information described in this Privacy Policy. Northeast Generals’ third-party partners may combine information collected about you through your use of the Sites with information they collect through other websites, apps or services you use. For more information on these third parties, including how to opt out from certain data collection

 

Third Party Analytics

 

Northeast Generals and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which Northeast Generals work use third-party analytics services (e.g., Google Firebase) to evaluate your use of the Sites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Sites and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide Northeast Generals the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. These third parties may collect any of the types of information described in this Privacy Policy. Northeast Generals’ third-party partners may combine information collected about you through your use of Northeast Generals’ Sites with information they collect through other websites, apps or services you use.

 

Video Content

 

Northeast Generals may collect, use and share information about videos you view on the Sites with Northeast Generals’ third-party partners as described in this Privacy Policy. Northeast Generals may also collect information from third parties regarding videos you view on third party sites. You agree and consent to this sharing and collection for two years or until you affirmatively withdraw consent. You may also be able to control information shared with Northeast Generals through third parties, such as social media services, through your privacy settings on those services.

 

By associating your social media or other third-party website account with your use of the Sites and authorizing Northeast Generals to have access to this information, you consent to this collection, use, and disclosure of video and content viewing information to these social media services and websites in accordance with this Privacy Policy.

 

How Does Northeast Generals Collect Information?

 

Your information is collected from Northeast Generals’ Sites, through email and/or through online applications or forms you complete, requests for Newsletters, requests for Northeast Generals or Site information, entering a sweepstakes or prize promotions, taking surveys, reporting problems, information you volunteer to Northeast Generals, and through any of your other activities with Northeast Generals. The Personal Information that Northeast Generals collects depends on the nature of your activities.

 

For example, Northeast Generals collect your information via the Contact and Newsletter sections of the Sites. Northeast Generals also collect information regarding your device, including GPS location when you use the Sites and associated services from your mobile device if your device has location services enabled. Northeast Generals also collects an identifier, device type, IP address, phone, browser type and version, time zone, browser plug-ins and versions, operating system and device platform.

 

How Does Northeast Generals Use the Information Northeast Generals Collects?

 

Personal Information you volunteer is used by Northeast Generals for internal verification, to complete requested transactions, to ensure appropriate legal use of Northeast Generals’ goods and/or services, to provide you notification about updates to the Sites, goods and services and to help provide you with technical support for the Sites.

 

For example, Northeast Generals uses the information it collects about you to:

 

Notify you of changes to the Sites or any of Northeast Generals’ agreements or policies, including this Privacy Policy;

 

Solicit your feedback about the Sites;

 

Communicate with you regarding messages you enter into the Contact form;

 

Deliver goods and services you request, purchase or subscribe for;

 

Enable Northeast Generals to provide, improve and maintain the Sites, including administration and internal operations such as data usage and analysis, research, testing, and troubleshooting;

 

Keep the Sites safe and secure;

 

Administer promotional programs;

 

Provide you, or permit selected third parties to provide you, with information and content, goods and services, that Northeast Generals feels may interest you, including internet-based or online advertisements, newsletters, brand or company promotions, re-targeted advertisements displayed on third party websites, and promotions, contests, and sweepstakes offered in partnership with third parties;

 

Measure or understand the effectiveness of advertising Northeast Generals and third party partners serve to you and others; and

 

Comply with administrative, regulatory and legal requirements.

 

We may anonymize personal information and share it in an aggregated form with third parties, advertisers and/or business partners in order to analyze the Sites, improve the Sites and user experience, or for other similar purposes. The use and disclosure of such anonymous information is not subject to any restrictions under this Privacy Policy.

 

How Does Northeast Generals Share Your Information with Third Parties?

 

We do not share your Personal Information with any third parties except as described in this Privacy Policy.

 

Northeast Generals may share information about you, including your Personal Information, with third parties, including to:

 

Business partners, suppliers and subcontractors to the extent necessary to assist Northeast Generals in providing and maintaining the Sites. For example, Northeast Generals may hire companies to help provide products or services, like a shipping company that may deliver packages, a marketing company that may deliver Northeast Generals’ Newsletters, a financial partner that assists in the completion of transactions you request, a prize may be provided by a third-party fulfillment company, or any other third party that is needed to assist in the completion of transactions or the provision of goods or services you request. Others include data processors, marketers, and customer service providers;

 

Service providers and business partners who supplement information Northeast Generals collects with additional information about visitors or users of the Sites and who help Northeast Generals better connect with Northeast Generals’ intended audience;

 

Analytics and search engine providers aid Northeast Generals in the improvement and optimization of the Sites;

 

Any of Northeast Generals’ parent companies, subsidiaries, joint ventures, or other companies under common control with Northeast Generals; and

 

To any other third party with your consent to do so.

 

Northeast Generals may also disclose your Personal Information:

 

In response to judicial or governmental subpoenas, warrants or orders served on Northeast Generals;

 

To protect Northeast Generals’ rights or property, to enforce the provisions of this Privacy Policy and/or any other Northeast Generals terms and conditions or agreements, and/or to prevent harm to yourself or to another;

 

In the event of a corporate sale, merger, reorganization, sale of assets, or dissolution of Northeast Generals; or

 

A petition for relief is filed under U.S. Bankruptcy laws for or against Northeast Generals or if Northeast Generals becomes subject to an order of appointment of a trustee or receiver.

 

Northeast Generals reserves the right to release and/or use all information contained within Northeast Generals’ databases, access logs or other records concerning you, including your Personal Information, if you violate this Privacy Policy, the Terms of Use, and any Northeast Generals terms and conditions, or other rules, policies, notices, agreements or guidelines, or if you intentionally or unintentionally partake (or are reasonably suspected of partaking) in any illegal activity, including but not limited to hacking, even without a subpoena, warrant or other court order, and to release such information in response to court and governmental orders, civil subpoenas, discovery requests and as otherwise required by law and/or to initiate Northeast Generals’ own legal proceedings. Northeast Generals cooperates with law enforcement agencies in identifying those who may be using the Sites (or any part thereof) for illegal activities. Northeast Generals also reserves the right to report any suspected illegal activity to law enforcement individuals or to entities for investigation or prosecution.

 

 

How Does Northeast Generals Share Information with Third-Party Internet-Based Advertising Companies?

 

Northeast Generals may share information about you, including your Personal Information, with third-party Internet-based advertising companies. This information is used to help such advertisers reach the kind of audience they want to target. This information is also used to assist such advertisers and advertising networks in selecting and serving relevant advertisements to you.

 

You may opt out of third-party interest-based advertising, by visiting www.networkadvertising.org and www.aboutads.info/choices for details on how to do so. Additionally, users of mobile devices can follow the below instructions:

 

Android Users

 

Open your Google Settings app from your app drawer, tap “Ads” and select “Opt out of interest-based ads.”

 

Google Account Users

 

For opting out via Google, regardless of device: See Google’s instructions for how to do click on the following – Google Ads Help.

 

iOS Users

 

Open the Settings app, select “Privacy,” scroll to the bottom and select “Advertising,” and tap to turn on “Limit Ad Tracking.”

 

What About Information Shared on Community Services?

 

Northeast Generals may make message boards, blogs, and other community services available to you on the Sites. Please understand that any information that is disclosed by you in these areas becomes public information. When you disclose such information on a message board, blog or any other public forum, you do so at your own risk. Northeast Generals has no control over its use and you should exercise caution when deciding to disclose your personal information or any other information about yourself. The information presented in these areas reflects the views of the individual users or hosts and does not necessarily reflect the views of Northeast Generals. Northeast Generals reserves the right (but has no obligation) to monitor the use of message boards, blogs or other public forums on the Sites.

 

Does Northeast Generals Use De-Identified Information?

 

Northeast Generals may take your Personal Information and make it non-personally identifiable, either by combining it with information about other individuals (aggregating your information with information about other individuals), or by removing characteristics (such as your name) that make the information personally identifiable to you (de-personalizing your information). Given the nature of this information, there are no restrictions under this Privacy Policy upon the right of Northeast Generals to aggregate or de-personalize your Personal Information, and Northeast Generals may use and/or share with third parties the resulting non-personally identifiable information in any manner in Northeast Generals’ sole discretion.

 

How Does Northeast Generals Maintain and Secure the Personal Information Northeast Generals Collects?

 

We make good faith efforts to provide you with access to your personal information and either to correct such data at your request if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. If you wish to request the correction or deletion of such data, you may contact Northeast Generals

 

Please note in order to protect the security of your information, you will be required to properly identify yourself before Northeast Generals can process such a request.

 

The security and confidentiality of your personal information is important to Northeast Generals and Northeast Generals will take reasonable measures to protect it, including measures to protect against unauthorized access, alteration, and disclosure. These security measures include, for example, internal reviews of Northeast Generals’ data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where Northeast Generals store personal data.

 

When the use of a Northeast Generals web page or app involves the transmission of Personal Information, Northeast Generals may use Secure Socket Layer (“SSL”) technology to establish a secure connection between your computer or device and Northeast Generals and/or the Sites. Northeast Generals may also allow the transmission of encrypted information from your computer or device to Northeast Generals and back again.

 

Northeast Generals reserves the right to monitor all network traffic to the Sites to identify and/or block unauthorized attempts or intrusions to upload or change information or cause damage to any of the Sites in any manner. Anyone using any of the Sites expressly consents to such monitoring.

 

Please be aware that no data transmission over the Internet or which is stored on a computer connected to the Internet can be guaranteed to be 100% secure, so while Northeast Generals strives to protect your personal information, Northeast Generals cannot ensure or warrant the security of any information that you voluntarily give to us.

 

Information provided via TrueDepth API technologies is stored on the device only for the duration of creating AR effects within the App. When the effect is rendered, the data is discarded.

 

Does Northeast Generals Use Cookies?

 

When you visit or use the Sites, Northeast Generals may place a cookie in a file directory on your computer or mobile device. A cookie is a small text file that is placed on your computer or mobile device to uniquely distinguish your visit to a website or use of an online service or mobile application. The information that cookies collect includes the date and time of your visit and your registration information. Cookies may offer you many conveniences for Northeast Generals’ Sites and allow Northeast Generals to recognize certain information, such as your browser type, so Northeast Generals knows if you can view certain plug-ins or extensions. They also allow Northeast Generals to streamline your visit to the Sites based on your previous visits.

 

Cookies may be either permanent or temporary. Northeast Generals may use both temporary and permanent cookies. A temporary or “session” cookie is placed on your computer or mobile device during your visit to any of Northeast Generals’ Sites and is deleted when you exit your Internet browser, the mobile application, and/or turn off your computer or device. A permanent or “persistent” cookie means that the cookie stays on your hard drive or mobile device until you delete it. You can delete Northeast Generals’ permanent cookie at any time by following the instructions contained in your browser’s help file, or by contacting the company providing your browser’s or mobile device’s technical support. Northeast Generals does not use cookies to store information such as credit card numbers, social security numbers or any other highly sensitive Personal Information.

 

You may also be able to reset or restrict the advertising cookies contained on your device or in your internet browser by accessing the privacy settings for such device and/or browser. Please follow the instructions contained in your browser’s help file, or by contacting the company providing your browser’s or mobile device’s technical support to do so, such as Apple for iOS devices.

 

You may configure your browser or device to accept or deny cookies from the Sites. However, disabling or denying cookies from the Sites may render parts of them inaccessible or may cause certain web pages or parts of the app not to properly load. There are also several services and websites which allow you to visit websites, including the Sites, anonymously. Again, you may not be able to access or use all of the content or services available on the Sites if you use these anonymizing services or websites. If you change computers or browsers or devices, or use multiple computers or browsers or devices or delete Northeast Generals’ cookies, you will need to repeat this process for each computer, each browser, and each device.

 

Does Northeast Generals Use Web Beacons/Pixel Tags?

 

Northeast Generals may use “Web Beacons,” sometimes referred to as “pixels,” “clear gifs,” or “web bugs,” which is another way (instead of cookies) to help personalize your experience on the Sites. Web Beacons are typically invisible to you and are generally embedded in very small clear graphics files. “Pixel Tags” are small strings of computer code that provide a method for delivering a graphic image on a web page or other medium. Pixel Tags allow Northeast Generals or a third party who serves the Pixel Tag, to set, read, and modify some of Northeast Generals’ cookies.

 

Northeast Generals may use Web Beacons and Pixel Tags to monitor certain non-personally identifiable information about you, including the URL of the page from which the Web Beacon or Pixel Tag originated, the type of browser used, the IP address of your computer and the time you viewed the Web Beacon or Pixel Tag. Northeast Generals may also use Web Beacons and Pixel Tags to assist Northeast Generals’ third-party advertising and/or content companies in providing the content they believe you want to see. Web Beacons and Pixel Tags are also used to allow such third parties to determine how many people view the advertisements and/or click through, and to assist in serving and managing advertisements and content. While Web Beacons and Pixel Tags do not collect Personal Information, the information collected by them may be used in conjunction with Cookies to identify aggregate information about users of the Sites.

 

What Happens with Do Not Track Requests?

 

Northeast Generals does not currently have the capabilities to recognize the Do Not Track signals from Internet browsers. Therefore, any selection you make within your Internet browser will not be applied to the Sites. For more information regarding Do Not Track you can visit www.allaboutdnt.org.

 

Links or Usage of Third Party Websites/App Stores

 

The Sites may contain links to third-party websites. Northeast Generals has no control over the privacy practices or the content of such third-party websites. Neither Northeast Generals, nor any of its officers, directors, partners, employees, agents, representatives, vendors or suppliers are responsible for the content, privacy policies, products, services, reliability, viewpoint or accuracy of information on any such websites. Northeast Generals does not control and is not responsible for the collection of personal information by third party websites, including websites owned or controlled by Northeast Generals’ preferred financial partners, advertisers, vendors and/or websites not controlled by Northeast Generals.

 

The app stores (e.g., App Store or Google Play) may collect certain information in connection with your use of the Sites, including Personal Information, geo-locational information, payment information, and other usage-based data. Northeast Generals has no control over the collection of such information by any third-party app store, and any such collection or use will be subject to such third-party app store’s applicable privacy policy.

 

For California Residents Only – Please Read

 

FOR RESIDENTS OF CALIFORNIA ONLY. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and have provided your personal information to Northeast Generals, you may request information about Northeast Generals’ disclosures of certain categories of personal information to third parties for direct marketing purposes.

 

Within thirty (30) days of receiving such a request, Northeast Generals will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. Northeast Generals reserves its right not to respond to requests submitted other than to the address specified in this Section, requests not labeled or sent properly, or requests that do not have complete information.

 

Governing Law/Jurisdiction

 

Our Sites are controlled and operated from Northeast Generals’ offices within the State of Massachusetts, United States of America. All Disputes are governed by the terms set forth in Northeast Generals’ Terms of Use.

 

If you are accessing Northeast Generals’ Sites from any location with regulations or laws governing personal data collection, use or disclosure that differ from United States of America laws or regulations, please note that through your continued use of Northeast Generals’ Sites, which is governed by the laws of State of Massachusetts, United States and this Privacy Policy,

you are transferring Personal Information to the United States of America and you consent to that collection, transfer to and any associated processing, usage and storing in the United States of America.

 

Opt-Out of Northeast Generals Communications

 

You may choose to opt-out of receiving electronic communications from us. To opt-out of electronic communications from Northeast Generals, please contact Northeast Generals at info@northeastgenerals.com to request that you be unsubscribed from any of Northeast Generals’ marketing emails. You should provide your name and email address(es) to us, so that Northeast Generals can do its best to ensure that you stop receiving such communications from us.

 

Changes to this Privacy Policy

 

Northeast Generals reserves the right to make changes to any terms of this Privacy Policy at any time, however, Northeast Generals shall provide notification to you in advance of any changes becoming effective, such as by posting a notification on the Sites or via email if you have provided Northeast Generals with your email address. If you continue to access and/or use any of the Sites after the effective date of such changes, then such access and/or use will be deemed an acceptance of and an agreement to follow and be bound by the terms as changed. The revised Privacy Policy supersedes all previous notices or statements regarding the Sites. For this reason, Northeast Generals encourages you to review this Privacy Policy any time you access or use the Sites, and Northeast Generals recommends that you print out a copy for your records.