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Privacy Policy

INVISIBLE NORTH WEBSITE PRIVACY POLICY

Last updated on May 3rd, 2023 (“Effective Date”)

INCO, LLC (“Invisible North,” “Company,” “we,” “our” or “us”) understands that privacy is important to our users, and this privacy policy (“Privacy Policy”) shows our commitment to your privacy. If you are interested in learning how we collect, use, and disclose information through our corporate website (the “Website”), including other related activities or interactions, such as when you email or otherwise contact us, you have come to the right place.

This Privacy Policy describes how we collect, use, share, and secure the personal information we collect via the Website and describes your choices and rights regarding that personal information. This Privacy Policy applies only to the information collected with respect to the Website and any other direct corporate interactions with us, such as when you email us or otherwise contact us directly. It does not apply to our core services that help our clients and partners with media and advertising.

“Personal information” or “personal data” is information that identifies, is reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, with a natural person and, where required by law, a household. This Privacy Policy does not apply to anonymous, de-identified, or aggregated personal information, which we reserve the right to use in any manner permitted by applicable law. Our goal is to be transparent about our business by describing our technology in simple terms so that users can understand our practices.

Please note that our privacy practices are subject to the applicable laws of the regions in which we operate. Accordingly, some additional region-specific terms will only apply to consumers located in those geographic regions, or as required by applicable law. 

TABLE OF CONTENTS:

  • WHAT PERSONAL INFORMATION DO WE COLLECT AND USE?
  • HOW DO WE COLLECT PERSONAL INFORMATION?
  • HOW DO WE USE YOUR PERSONAL INFORMATION?
  • SHARING OF YOUR PERSONAL INFORMATION
  • HOW IS THE INFORMATION STORED AND HOW LONG IS IT KEPT?
  • YOUR CHOICES
  • YOUR RIGHTS
  • Your California Privacy Rights
  • Your Nevada Privacy Rights 
  • Your Virginia Privacy Rights 
  • Your European Privacy Rights 
  • TRANSMISSION OF INFORMATION TO OTHER COUNTRIES
  • CHILDREN’S PRIVACY
  • SECURITY
  • CONTACTING US
  • CHANGES TO THIS POLICY

WHAT PERSONAL INFORMATION DO WE COLLECT AND USE?

We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal information. The precise definition of personal information may vary depending on your place of residence, but we take the same general approach to protecting your privacy, subject to any additional measures that may be required by applicable laws. 

The following are the categories and types of personal information that we may collect from or about you, depending on how you interact with the Website:

  • Identifiers, such as your name and email address;
  • Device and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers;
  • Internet or other electronic network activity information, including, but not limited to browsing history, search history, and information regarding your interaction with an internet website, application, mobile app, or advertisement;
  • Geolocation or other information that permits us to determine your location;
  • Any other personal information that you voluntarily provide us.

 

HOW DO WE COLLECT PERSONAL INFORMATION?

Personal Information You Provide

We collect personal information that you provide to us directly. This may include, but is not limited to:

  • Information you provide when you contact us via email or text message, or through other Internet-enabled communications;
  • [Information you provide to us in person, over the telephone, or via regular mail];
  • Information you provide when you [register to use our Website,] [create a profile or account,] or [subscribe to one of our Services];
  • Content that you post to the Website;
  • Your responses to surveys that you choose to complete for us;
  • Information you provide when you enter a contest or other promotion sponsored by us;
  • Details relating to transactions that you carry out through our Website, including any orders that you ask us to fulfill, and any payment or other financial information you provide to us relating to such orders;
  • Your search queries on the Website;
  • Any other information that you provide us on or through the Website.

 

Personal Information We Collect Automatically

 

HOW DO WE USE YOUR PERSONAL INFORMATION?

We collect and use personal information for the following purposes:

To communicate with you, which may include:

  • Contacting you about and providing you and our clients with our Services;
  • Responding to your direct inquiries, requests, issues or feedback, and providing customer service;
  • Adding you to our mailing lists and sending you emails from time to time;

To provide our products and services, which may include: 

  • Operating the Website, and providing you with any specific services that you have requested;
  • Creating, maintaining, and otherwise managing your account, profile, or subscription;
  • Delivering content and product and service offerings relevant to your interests;
  • Fulfilling your orders and/or completing the transactions you have requested, processing your payments, and providing you receipts and order updates;
  • Providing a forum for discussion, asking questions, posting photos and reviews, and sharing experiences;

For marketing and promotional purposes, which may include:

  • Marketing Company goods and services or goods and services of those of our affiliates, business partners, and other third parties;
  • Providing you advertising for products and services that may be of interest to you;
  • Administering sweepstakes, contests, and other similar promotions;

For analytics and personalization, which may include: 

  • Identifying trends and making inferences about you and your interactions with us or our affiliates or our business partners;
  • Conducting research and analytics to improve our services and product offerings or those of our affiliates and business partners; 
  • Understanding how you interact with our Website, advertisements, and communications with you to determine which of our products or services are the most popular, and to improve Website and marketing campaigns; 
  • Personalizing your experience to save you time when you visit our Website [or visit us in person], and to customize the marketing and advertising that we show you; 
  • Better understanding our customers’ needs;
  • Providing personalized recommendations about our products and services;

For security and fraud prevention, which may include: 

  • Helping maintain the safety, security, and integrity of our Website, databases and other technology assets, and business;
  • Internal research; technological development and demonstration; and improving, upgrading, or enhancing our Website;
  • Detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity;
  • Investigating suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for our Website;

To comply with legal obligations, which may include: 

  • Compliance with legal or regulatory obligations, establishing or exercising our rights, and to defending against a legal claim;
  • Responding to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation;
  • Acting in connection with a bankruptcy proceeding or the sale, merger, or change of control of the Company or the division responsible for the services with which your information is associated;

To support core business functions, which may include: 

  • Maintaining records related to business process management, loss and fraud prevention, and to collect amounts owing to us; 
  • Providing and provide and maintaining the functionality of our Website, including identifying and repairing errors or problems; and

For any additional purposes that you specifically consent to.

SHARING OF YOUR PERSONAL INFORMATION

In addition to using your personal information ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal information to other affiliates and entities in the following instances:

  • Service Providers

We may share your personal information with third-party service providers who may use your information to provide us with services including, but not limited to: website hosting, data analysis, infrastructure provision, information technology services, customer service, email delivery services, payment processing, auditing, and anti-fraud monitoring. These service providers may have access to personal information that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

  • Corporate Affiliates 

We may share personal information with our corporate affiliates and subsidiaries, who process personal information on our behalf, where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.

  • Business and Advertising Partners

We may share your personal information with third parties who partner with us to promote products and services, provide marketing and advertisements, conduct data analytics, or use the data for other commercial purposes. We do not control how these third parties use and share your personal information once they receive it. You will need to contact such third parties directly for information about their privacy practices or to exercise any rights you may have (including if you would like to opt-out of marketing messages).

  • Legal Compliance and to Defend Our Rights

We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

  • Business Transfers

We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Website.

  • Non-Personal Information

We may share non-personal information with unaffiliated third parties, such as business and advertising partners, manufacturers, distributors, and retailers, to improve and enhance your experience using the Website, and for our own market research activities. We publicly commit to maintain and use the information in de-identified or aggregate form, and not to attempt to re-identify the information.  

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

INTEREST BASED ADVERTISING

YOUR CHOICES

Consistent with applicable law, you may exercise the options described in this section regarding your choices with respect to your personal information and communications from us. You may also have certain additional rights available under state law depending on your state or country of residence, as described further below.

  • Cookies and Tracking

If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Website or some of its functionality may be affected. 

For clarity, cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Additionally, if you opt out on one of your devices, that opt out may not be effective on all of your devices. You must separately opt out on each device. 

Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. However, if you are a resident of California, Virginia or Colorado, we treat Global Privacy Control signals as a means of opting out of the sale or sharing of personal information, or of opting out of the processing of personal information for targeted advertising, as applicable. Please see the sections titled California Privacy Rights and Virginia, Colorado, Connecticut and Utah Privacy Rights below for more information.

  • Interest-Based Advertising

You may opt out of receiving targeted ads from certain data and advertising partners that participate in certain industry self-regulatory programs. The DAA provides a website at www.aboutads.info/consumers with information about how to opt out of targeted advertising from some or all of the DAA’s participating companies. Additionally, the Network Advertising Initiative (“NAI”) offers a website at http://optout.networkadvertising.org/ where you can opt out of interest-based advertising from some or all of the NAI’s members. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities.

For targeted advertisements delivered through mobile apps, users may opt out of certain ads or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, visit the following links: 

  • iOS – https://support.apple.com/en-us/HT202074
  • Android – https://support.google.com/ads/answer/2662922?hl=en

You can also install the DAA’s AppChoices app on your device to opt out of targeted advertising by certain providers, and to select system-level advertising preferences on your device (such as “Limit Ad Tracking” on Apple devices, or “Opt-out of Interest-based ads” on Android devices). 

Finally, to learn more from the NAI about how to opt out of targeted advertising on mobile devices, you can also visit the following link: https://thenai.org/opt-out/mobile-opt-out/.

YOUR RIGHTS

These additional privacy right disclosures provide additional information about our personal information processing practices relating to individual residents of the applicable jurisdictions. Unless otherwise expressly stated, all defined terms in this Privacy Policy retain the same meaning in the disclosures below. The rights, to the extent those rights are applicable set forth below are granted only to the extent they apply and are enforceable in an applicable jurisdiction.

Your California Privacy Rights

These provisions apply only to California consumers and supplement this Privacy Policy. The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws,” provide California consumers with specific rights regarding their personal information. This California Privacy Rights section describes your rights under the California Consumer Privacy Laws, explains how you may exercise your rights, and provides an overview on the types of personal information we collect. (When we refer to personal information throughout this section, we mean “personal information” as defined under the California Consumer Privacy Laws).

The California Consumer Privacy Laws provide you with the following rights:

  • Right to know. You have the right to know what categories and specific pieces of personal information we collect about you, the sources from which we collect personal information, our business or commercial purpose for the collection, use, and sharing of your personal information, and any categories of third parties to whom we sell or with whom we share your personal information.  
  • Right to data portability. You have the right to request a copy of personal information we have collected and maintained about you in the past 12 months. California Consumer Privacy Laws allow you to request your information from us up to twice during a twelve (12) month period.  We will provide our response in a readily usable format, which is usually electronic.
  • Right to delete. You have the right to request that we delete the personal information that we have collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your personal information, we may deny your request or may retain certain elements of your personal information if it is necessary for us or our service providers to:
  • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  • Debug to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
  • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
  • Right to opt out of selling or sharing. At the time this Privacy Policy was last updated, we (1) DO NOT SELL personal information; and (2) we DO NOT SHARE personal information for the purpose of cross-context behavioral advertising. 

If at any time we do sell or share your personal information, you have the right to opt out of the sale or sharing of your personal information, along with the right to opt in to the sale of such information. If we sell or share any of your personal information, you may, at any time, tell us not to sell or share your personal information. You can make this request through the methods described below.  

  • Right to correct. You have the right to request the correction of any personal information we maintain about you. 
  • Right to limit use or disclosure of sensitive personal information (“SPI”). Please note that we do not currently use or disclose sensitive personal information (“SPI”) for any purposes that require disclosure or opt out under the California Consumer Privacy Laws as we understand those laws. You have the right to limit the use or disclosure of your SPI if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services. 
  • Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services. 
    • Suggest that you may receive a different price or rate for goods or services. 

 

How to Contact Us About Your California Privacy Rights

You can submit a request to access, delete, limit, or correct your personal information, in addition to withdrawing consent and requesting to opt-out, using the methods below.

  • Calling us at 212 603 9171
  • Emailing us at Hello@InvisibleNorth.com 
  • Verification of Your Identity. After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In order to verify your identity, we will request, at a minimum, that you provide your name, email address, phone number, address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.

Except as required by law, only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your personal information. If you are making a request as the authorized agent of a California consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. 

Our Response Time to Your Request

We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, the California Consumer Privacy Laws allow us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond.

California Metrics

California “Shine the Light”

In addition to the above rights, under California Civil Code Section 1798.83 (“Shine the Light”), California residents may have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at Hello@InvisibleNorth.com If you do not want your personal information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at Hello@InvisibleNorth.com

Your Nevada Privacy Rights 

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at Hello@InvisibleNorth.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

VIRGINIA, COLORADO, CONNECTICUT AND UTAH PRIVACY RIGHTS

Residents of Virginia, Colorado, Connecticut and Utah (“States”) have certain rights with respect to their personal information.  These rights are established through the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Utah Consumer Privacy Act (“UCPA”) (collectively, the “State Laws”).  The rights available to residents of these States are explained below. 

The categories of personal information we process, our purposes for processing your personal information, the categories of personal information that we share with third parties, and the categories of third parties with whom we share it are set forth in the details of our Privacy Policy above. 

Rights to Your Information

In addition to the rights set forth in our Privacy Policy, the State Laws provide you with the following rights, except where indicated otherwise below:

  • Right to know. You have the right to know whether we process your personal information and to access such personal information. 
  • Right to data portability. You have the right to obtain a copy of your personal information that you previously provided to us or that we have obtained in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. Subject to certain exceptions, you may request such personal information free of charge once annually, except for Virginia residents, who may request such personal information up to twice annually. 
  • Right to delete. Residents of Virginia, Colorado and Utah have the right to delete personal information that you have provided to us or that we have obtained about you; requests from Utah residents cover only personal information that you have provided directly to us. Please note that we may deny requests to delete if the requested deletion falls under an exception as set forth the applicable State Laws. Additionally, if you request deletion of your personal information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your personal information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such personal information for any purpose except for those allowed under the applicable State Laws.
  • Right to opt out. Residents of Virginia, Colorado, Connecticut and Virginia have the right to opt out of the processing of the personal information for purposes of: (i) targeted advertising; (ii) the sale of personal information; or (iii) profiling that produces legal or similarly significant effects concerning you. Utah residents may opt out of the processing for the purposes described in (i) and (ii) of this paragraph.

 As of the Effective Date of the Privacy Policy:

  • We DO NOT  process personal information for the purposes of targeted advertising;
  • We DO NOT sell your personal information in exchange for monetary consideration; and
  • We DO NOT engage in profiling decisions based on your personal information that produce legal or similarly significant effects concerning you.
  • Right to correct. Residents of Virginia, Colorado and Connecticut have the right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process it. 
  • Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your Virginia privacy rights. Unless permitted by applicable State Law, we will not:
    • Deny you goods or services;
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
    • Provide you a different level or quality of goods or services; or 
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights; Verifying Your Identity

To exercise any of your State Law privacy rights, or if you have any questions about your privacy rights, you may contact us by:

 

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that your request is not fraudulent. We may contact you for additional information as reasonably necessary to authenticate your request, but if we are ultimately unable to authenticate your request using reasonably commercial efforts, then we may not be able to comply with it.

Only you may make a verifiable request related to your personal information. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal information, we may ask you to submit reliable proof of your identity.

Response Time; Your Right to Appeal

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the certain State Laws allow an extension of our time to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive. 

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so. and, for Virginia, Colorado and Connecticut residents, provide instructions for how to appeal the decision. Residents of those will have the right to appeal within a reasonable period of time after you have received our decision. Within the time provided by your State Law of our receipt of your 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 we deny your appeal, we will provide you with a method for contacting the your state’s regulatory authority to submit a complaint.

Sensitive Data

The State Laws of Virginia, Colorado and Connecticut require companies to obtain a consumer’s affirmative consent before processing “sensitive data,” which may include, depending on the specific statute, information that reveals: 

  • Geolocation data
  • Racial or ethnic origin
  • Religious beliefs
  • A mental or physical health condition or diagnosis
  • Sex life or sexual orientation
  • Citizenship or citizenship status
  • Genetic data
  • Biometric data
  • Personal data regarding a known child
  • Contents of email
  • Social Security or other ID

 

We will not process any such sensitive data from Virginia, Colorado, or Connecticut residents without first obtaining your consent. Additionally, for Colorado residents, we will not process any sensitive data inferences with first obtaining your consent.

Your European Privacy Rights 

TRANSMISSION OF INFORMATION TO OTHER COUNTRIES

Invisible North is located in the United States.

If you submit personal information to Invisible North, , your personal information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence including, but not necessarily limited to, the United States.

CHILDREN’S PRIVACY

Children under 16 years of age are not permitted to use the Website, and we do not knowingly collect information from children under the age of 16. By accessing the Website or using any services available through the Website, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so. 

SECURITY

Invisible North uses industry-standard technical and organizational security measures to help protect information transmitted over or stored on our systems. Please note, however, that no transmission or storage of information can ever be guaranteed to be completely secure, though we do take all reasonable precautions to protect against security incidents.

CONTACTING US

If you have any questions about our privacy or security practices, you can contact us by mail, telephone, or email:

55 Washington Street
Brooklyn, NY 11205
212 603 9171 

CHANGES TO THIS POLICY

We update this Privacy Policy from time to time in our discretion and will notify you of any material changes to the way in which we treat personal information by posting an updated privacy policy or other notice on relevant areas of the Website. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Website after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your personal information in a manner materially different from what was stated at the time your personal information was collected.