Last updated: December 7, 2023
Your privacy is important to us. It is 20 North, Inc. and its related companies (“20North”) policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, and other sites we own and operate. Capitalized terms not defined in this privacy policy have the meanings given in our Terms of Service. Your use of any of our Services, including the Sites, constitutes your acceptance of the terms of this privacy policy.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.
In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.
Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.
“Voluntarily provided” information refers to any information you knowingly and activelyprovide us when using or participating in any of our services and promotions.
“Automatically collected” information refers to any information automatically sent by yourdevices in the course of accessing our products and services.
When you visit our website, our servers may automatically log the standard data providedby your web browser. It may include your device’s Internet Protocol (IP) address, yourbrowser type and version, the pages you visit, the time and date of your visit, the timespent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the site, we may automaticallycollect data about the error and the circumstances surrounding its occurrence. This datamay include technical details about your device, what you were trying to do when theerror happened, and other technical information relating to the problem. You may or maynot receive notice of such errors, even in the moment they occur, that they have occurred,or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, itmay be possible to combine it with other data to personally identify individual persons.
When you visit our website or interact with our services, we may automatically collect data about your device. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server),device and application identification numbers, location, browser type, hardware model,Internet service provider and/or mobile carrier, operating system, and system configuration information.
Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based onyour IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.However, if you choose to opt out, you may not be able to use certain aspects of theServices.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. We may ask for personal information — for example, when you contact us — we may ask for one or more of the following:
Transaction data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.
We process your personal information for a variety of reasons, depending on how you interact with our Services. We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you provide us with your location, we may combine this with general information about currency and language to provide you with an enhanced experience of our site and service.
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy.
For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
We do not aim any of our products or services directly at children under the age of 18, and we do not knowingly collect personal information about children under 18. By using theServices, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at legal@20northmarketing.com
We may disclose personal information to:
We may share your data with third-party vendors, service providers, contractors, or agents(“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.The categories of third parties we may share personal information with are as follows:
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored and processed by us in our facilities and by those third parties with whom we may share your personal information.
The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information.If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. Again, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example processing transaction data), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from our email database or opt-out of communications(including marketing communications), please contact us at legal@20northmarketing.com using the details provided in this privacy policy or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.
The GDPR distinguishes between organizations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We, 20North, located at the address provided in our Contact Us section, are a Data Controller with respect to the personal information you provide to us.
We will only collect and use your personal information when we have a legal right to do so.In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 18 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.
Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. You may consent to providing your email address for the purpose of receiving marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you purchase a product, service, or subscription from us, we may need to use your personal and payment information in order to process and deliver your order.
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
In some cases, we may have a legal obligation to use or keep your personal information.Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.
Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There maybe exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 365 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.
Some browsers have a “Do Not Track”(“DNT”) feature that lets you tell websites that you do not want to have your online activities tracked. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about the practice in a revised version of this privacy.
We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies, this could affect certain features or services of our Services.
At all times, you may decline cookies from our site if your browser permits. Most browsers allow you to activate settings on your browser to refuse the setting of all or some cookies. Accordingly, your ability to limit cookies is based only on your browser’s capabilities. Please refer to the Cookies section of this privacy policy for more information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below
If you are under 18 years of age, reside in California, and have a registered account with Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.)
The California Code of Regulations defines a “resident” as
All other individuals are defined as "non-residents."
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information
YES
C. Protected classification characteristics under California or federal law
Gender and date of birth
NO
D. Commercial information
Transaction information, purchase history, financial details, and payment information
YES
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
YES
G. Geolocation data
Device location
YES
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with out business activities
YES
I. Professional or employment-related information
Business contact details in order to provide you with our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
YES
J. Education Information
Student records and directory information
NO
K. Inferences are drawn from other personal information
Inferences are drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics
NO
L. Sensitive Personal Information
NO
We will use and retain the collected personal information as needed to provide the Services or for:
Category A - As long as the user has an account with us
Category B - As long as the user has an account with us
Category D - As long as the user has an account with us
Category G - As long as the user has an account with us
Category H - As long as the user has an account with us
Category I - As long as the user has an account with us
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
20 North, Inc collects and shares your personal information through:
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal information.
20North has disclosed the following categories of personal information to third parties fora business or commercial purpose in the preceding twelve (12) months:
20 North, Inc. has not sold any personal information to third parties in the preceding twelve (12) months.
More information about our data collection and sharing practices can be found in this Privacy Policy in the Cookies and Pixels subheading of Section 10.
For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section (Section 1) of this Privacy Policy. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.
You may contact us by email at legal@20northmarketing.com for any further questions or requests in regards to any of the information provided but specifically in opting out of selling or sharing of your personal information.
Right to Know and Delete
If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities. Depending on your circumstances, you have the right to request the following from us:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for the security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
To exercise these rights, you can contact us by email at legal@20northmarketing.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use and disclose about you will vary depending on how you interact with 20North and our Services. To find out more, please see the following sections of this privacy policy
Your rights with respect to you personal data
20North has not sold any personal data to third parties for business or commercial purposes. 20North will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy policy notice.
To exercise these rights, you can contact us by email at legal@20northmarketing.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify that it is you before processing your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and the reasoning behind it. If you wish to appeal our decision, please email us at legal@20northmarketing.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.
Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
We are located in Georgia, U.S.A. and this privacy policy will be governed by Georgia law without regard to any conflict of law principles. Your information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of information may be less stringent than the laws in your country. By using any of the Services, you consent to the collection, transfer, use, storage and disclosure of your information as described in this privacy policy and submitted to the jurisdiction of and within the State of Georgia.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
We encourage you to review this privacy notice frequently to be informed of how we are protecting information.
Annual Review and Audit
If you have any questions or concerns about this privacy policy or your Personally Identifiable Information, please contact us at:
20 North, Inc.,
Attention: Legal
3525 Piedmont Rd. Ste 8-520
Atlanta, GA 30305
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact
