Howfinity (howfinity.com & howfinitycourse.com) understands that your privacy is important to you.

We are committed to protecting the privacy of your personally-identifiable information as you

use this website. This Privacy Policy tells you how we protect and use information that we

gather from you. By using this website, you consent to the terms described in the most recent

version of this Privacy Policy. You should also read our Terms of Use to understand the general

rules about your use of this website, and any additional terms that may apply when you access

particular services or materials on certain areas of this website. “We,” “our” means

Howfinity (howfinity.com/howfinitycourse.com) and its affiliates. “You,” “your,” visitor,” or “user” means the

individual accessing this site.

PERSONAL AND NON-PERSONAL INFORMATION

Our Privacy Policy identifies how we treat your personal and non-personal information.

WHAT IS NON-PERSONAL INFORMATION AND HOW IS IT COLLECTED AND USED?

Non personal information is information that cannot identify you. If you visit this web site to

read information, such as information about one of our services, we may collect certain nonpersonal

information about you from your computer’s web browser. Because non-personal

information cannot identify you or be tied to you in any way, there are no restrictions on the

ways that we can use or share non-personal information.

WHAT IS PERSONAL INFORMATION AND HOW IS IT COLLECTED?

Personal information is information that identifies you as an individual, such as your name,

mailing address, e-mail address, telephone number, and fax number. We may collect personal

information from you in a variety of ways:

✓ When you send us an application or other form

✓ When you conduct a transaction with us, our affiliates, or others

✓ When we collect information about in you in support of a transaction, such as credit card

information

 

PRIVACY POLICY

In some places on this web site you have the opportunity to send us personal information

about yourself, to elect to receive particular information, to purchase access to one of our

products or services, or to participate in an activity.

ARE COOKIES OR OTHER TECHNOLOGIES USED TO COLLECT PERSONAL

INFORMATION?

Yes, we may use cookies and related technologies, such as web beacons, to collect

information on our website. A cookie is a text file that is placed on your hard disk by a web

page server. Cookies cannot be used to run programs or deliver viruses to your computer.

Cookies are uniquely assigned to you, and can only be read by a web server in the domain

that issued the cookie to you. One of the primary purposes of cookies is to provide a

convenience feature to save you time. The purpose of a cookie is to tell the Web server that

you have returned to a specific page. For example, if you register with us, a cookie helps

Howfinity (howfinity.com/howfinitycourse.com) to recall your specific information on subsequent

visits. This simplifies the process of recording your personal information, such as billing

addresses, shipping addresses, and so on.

When you return to the same howfinity.com & howfinitycourse.com website, the information you previously

provided can be retrieved, so you can easily use the features that you customized. A web

beacon is a small graphic image that allows the party that set the web beacon to monitor and

collect certain information about the viewer of the web page, web-based document or e-mail

message, such as the type of browser requesting the web beacon, the IP address of the

computer that the web beacon is sent to and the time the web beacon was viewed. Web

beacons can be very small and invisible to the user, but, in general, any electronic image

viewed as part of a web page or e-mail, including HTML based content, can act as a web

beacon. We may use web beacons to count visitors to the web pages on the web site or to

monitor how our users navigate the web site, and we may include web beacons in e-mail

messages in order to count how many messages sent were actually opened, acted upon or

forwarded.

Third party vendors also may use cookies on our web site. For instance, we may contract with

third parties who will use cookies on our web site to track and analyze anonymous usage and

volume statistical information from our visitors and members. Such information is shared

externally only on an anonymous, aggregated basis. These third parties use persistent cookies

to help us to improve the visitor experience, to manage our site content, and to track visitor

behavior. We may also contract with a third party to send email to our registered [users/

members].

To help measure and improve the effectiveness of our e-mail communications, the third party

sets cookies. All data collected by this third party on behalf of Howfinity (howfinity.com

howfinitycourse.com)

is used solely by or on behalf of Howfinity and is shared externally only

on an anonymous, aggregated basis. From time to time we may allow third parties to post

advertisements on our web site, and those third-party advertisements may include a cookie or

web beacon served by the third party. This Privacy Policy does not cover the use of information

collected from you by third party ad servers. We do not control cookies in such third party ads,

and you should check the privacy policies of those advertisers and/or ad services to learn

about their use of cookies and other technology before linking to an ad.

We will not share your personal information with these companies, but these companies may

use information about your visits to this and other websites in order to provide advertisements

on this site and other sites about goods and services that may be of interest to you, and they

may share your personal information that you provide to them with others.

You have the ability to accept or decline cookies. Most Web browsers automatically accept

cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you

choose to decline cookies, you may not be able to fully experience the interactive features of

the howfinity.com and howfinitycourse.com websites you visit.

HOW DOES HOWFINITY USE PERSONAL INFORMATION?

Howfinity (howfinity.com/howfinitycourse.com) may keep and use personal information we collect

from or about you to provide you with access to this web site or other products or services, to

respond to your requests, to bill you for products/services you purchased, and to provide

ongoing service and support, to contact you with information that might be of interest to you,

including information about products and services of ours and of others, or ask for your opinion

about our products or the products of others, for record keeping and analytical purposes and to

research, develop and improve programs, products, services and content.

Personal information collected online may be combined with information you provide to us

through other sources. We may also remove your personal identifiers (your name, email

address, social security number, etc). In this case, you would no longer be identified as a

single unique individual. Once we have de-identified information, it is non-personal information

and we may treat it like other non-personal information. Finally, we may use your personal

information to protect our rights or property, or to protect someone’s health, safety or welfare,

and to comply with a law or regulation, court order or other legal process.

DOES HOWFINITY SHARE PERSONAL INFORMATION WITH OTHERS?

We will not share your personal information collected from this web site with an unrelated third

party without your permission, except as otherwise provided in this Privacy Policy. In the

ordinary course of business, we may share some personal information with companies that we

hire to perform services or functions on our behalf. In all cases in which we share your

personal information with a third party for the purpose of providing a service to us, we will not

authorize them to keep, disclose or use your information with others except for the purpose of

providing the services we asked them to provide.

We will not sell, exchange or publish your personal information, except in conjunction with a

corporate sale, merger, dissolution, or acquisition. For some sorts of transactions, in addition to

our direct collection of information, our third party service vendors (such as credit card

companies, clearinghouses and banks) who may provide such services as credit, insurance,

and escrow services may collect personal information directly from you to assist you with your

transaction. We do not control how these third parties use such information, but we do ask

them to disclose how they use your personal information before they collect it. If you submit a

review of the Howfinity (howfinity.com/howfinitycourse.com), during the submission process we ask

your permission to gather your basic information (such as name and email address) which we

then share with the third party for whom you are submitting the review. We may be legally

compelled to release your personal information in response to a court order, subpoena, search

warrant, law or regulation.

We may cooperate with law enforcement authorities in investigating and prosecuting web site

visitors who violate our rules or engage in behavior, which is harmful to other visitors (or

illegal). We may disclose your personal information to third parties if we feel that the disclosure

is necessary to protect our rights or property, protect someone’s health, safety or welfare, or to

comply with a law or regulation, court order or other legal process. As discussed in the section

on cookies and other technologies, from time to time we may allow a third party to serve

advertisements on this web site.

If you share information with the advertiser, including by clicking on their ads, this Privacy

Policy does not control the advertisers use of your personal information, and you should check

the privacy policies of those advertisers and/or ad services to learn about their use of cookies

and other technology before linking to an ad.

HOW IS PERSONAL INFORMATION USED FOR COMMUNICATIONS?

We may contact you periodically by e-mail, mail or telephone to provide information regarding

programs, products, services and content that may be of interest to you. In addition, some of

the features on this web site allow you to communicate with us using an online form. If your

communication requests a response from us, we may send you a response via e-mail. The email

response or confirmation may include your personal information. We cannot guarantee

that our e-mails to you will be secure from unauthorized interception.

HOW IS PERSONAL INFORMATION SECURED?

We have implemented generally accepted standards of technology and operational security in

order to protect personally-identifiable information from loss, misuse, alteration, or destruction.

Only authorized personnel and third party vendors have access to your personal information,

and these employees and vendors are required to treat this information as confidential.

Despite these precautions, we cannot guarantee that unauthorized persons will not obtain

access to your personal information.

 

LINKS

This site contains links to other sites that provide information that we consider to be interesting.

Howfinity (howfinity.com/howfinitycourse.com) is not responsible for the privacy practices or the

content of such web sites.

INTELLECTUAL PROPERTY RIGHTS

You must not:

• Republish material from our website without prior written consent.

• Sell or rent material from our website.

• Reproduce, duplicate, create derivative, copy or otherwise exploit material on our website for

any purpose.

• Redistribute any content from our website, including onto another website.

 

Acceptable Use

You agree to use our website only for lawful purposes, and in a way that does not infringe the

rights of, restrict or inhibit anyone else’s use and enjoyment of the website. Prohibited behavior

includes harassing or causing distress or inconvenience to any other user, transmitting

obscene or offensive content or disrupting the normal flow of dialogue within our website.

You must not use our website to send unsolicited commercial communications. You must not

use the content on our website for any marketing related purpose without our express written

consent.

 

Restricted Access

We may in the future need to restrict access to parts (or all) of our website and reserve full

rights to do so. If, at any point, we provide you with a username and password for you to

access restricted areas of our website, you must ensure that both your username and

password are kept confidential.

 

Use of Testimonials

In accordance to with the FTC guidelines concerning the use of endorsements and

testimonials in advertising, please be aware of the following:

Testimonials that appear on this site are actually received via text, audio or video submission.

They are individual experiences, reflecting real life experiences of those who have used our

products and/or services in some way. They are individual results and results do vary. We do

not claim that they are typical results. The testimonials are not necessarily representative of all

of those who will use our products and/or services.

The testimonials displayed in any form on this site (text, audio, video or other) are reproduced

verbatim, except for correction of grammatical or typing errors. Some may have been

shortened. In other words, not the whole message received by the testimonial writer is

displayed when it seems too lengthy or not the whole statement seems relevant for the general

public.

Howfinity is not responsible for any of the opinions or comments posted on

Howfinity (howfinity.com/howfinitycourse.com) is not a forum for testimonials, however provides testimonials

as a means for customers to share their experiences with one another. To protect against

abuse, all testimonials appear after they have been reviewed by management of

Howfinity (howfinity.com/howfinitycourse.com) does not share the opinions, views or commentary of any

testimonials on howfinity.com/howfinitycourse.com the opinions are strictly the views of the testimonial

source.

PUBLIC DISCUSSIONS

This site may provide public discussions on various business valuation topics. Please note that

any information you post in these discussions will become public, so please do not post

sensitive information in the public discussions. Whenever you publicly disclose information

online, that information could be collected and used by others. We are not responsible for any

action or policies of any third parties who collect information that users disclose in any such

forums on the web site. Howfinity does not agree or disagree with anything posted

on the discussion board. Also remember that you must comply with our other published

policies regarding postings on our public forums.

HOW CAN A USER ACCESS, CHANGE, AND/OR DELETE PERSONAL INFORMATION?

You may access, correct, update, and/or delete any personally-identifiable information that you

submit to the web site. You may also unsubscribe from mailing at any time by selecting the

“unsubscribe” option at the bottom of any email from Howfinity.

 

CHILDREN’S PRIVACY

Howfinity will not intentionally collect any personal information (such as a child’s

name or email address) from children under the age of 13. If you think that we have collected

personal information from a child under the age of 13, please contact us.

 

CHANGES

Howfinity reserves the right to modify this statement at any time. Any changes to

this Privacy Policy will be listed in this section, and if such changes are material, a notice will

be included on the homepage of the web site for a period of time.

 

Data Protection Policy

Howfinity is committed to providing a superior learning experience for everyone we

work with. We know that our users are committed to their success and we are equally

committed to ensuring that each interaction that someone has with our content is optimized for

maximum educational potential. To enable us to do this, Howfinity needs to gather

and use certain information about individuals.

Individuals who we gather information about includes customers, affiliates, business contacts,

employees, and other people the organization has a relationship with or may need to contact.

This policy describes how this personal data is collected, handled, and stored to meet the

company’s data protection standards — and to comply with the law.

Why This Policy Exists

This data protection policy ensures Howfinity:

✓ Complies with data protection law and follows industry best practices

✓ Protects the rights of staff, customers, affiliates, and partners

✓ Is open about how it stores and processes individuals’ data

✓ Protects itself from the risks of a data breach

EU General Data Protection Regulation (GDPR) Protection Law

The GDPR (General Data Protection Regulation) protection law describes how organizations

who conduct business with individuals or entities located in EU (European Union) nations —

including Howfinity — must collect, handle, and store personal information. These

rules apply regardless of whether data is stored electronically, on paper, or in any other

manner. To comply with the law, personal information must be collected and used fairly, stored

safely, and not disclosed unlawfully.

The EU GDPR is underpinned by eight core principles. These state that personal data

must:

✓ Be processed fairly and lawfully

✓ Be obtained only for specific, lawful purposes

✓ Be adequate, relevant, and not excessive

✓ Be accurate and kept up to date

✓ Not be held for any longer than necessary

✓ Processed in accordance with the rights of data subjects

✓ Be protected in appropriate ways

Not be transferred outside the European Economic Area (EEA), unless that country or territory

also ensures an adequate level of protection.

 

Policy Statement

Every day our business will receive, use, and store personal information about our customers,

affiliates, partners, and colleagues. It is important that this information is handled lawfully and

appropriately, in line with the requirements of the Data Protection Act 2018 and the General

Data Protection Regulation (collectively referred to as the ‘Data Protection Requirements’). We

take our data protection duties seriously, because we respect the trust that is being placed in

us to use personal information appropriately and responsibly.

 

About This Policy

This policy and any other documents referred to in it, sets out the basis on which we will

process any personal data that we collect or process. This policy does not form part of any

employee’s contract of employment and may be amended at any time. The company as a

whole is responsible for ensuring compliance with the Data Protection Requirements and with

this policy. Any questions about the operation of this policy or any concerns that the policy has

not been followed should be referred in the first instance to the Data Protection Officer.

 

What is Personal Data?

Personal data is defined as data, (whether stored electronically or paper based) relating to a

living individual who can be identified directly or indirectly from that data, (or from that data and

other information in our possession). Processing is any activity that involves use of personal

data. It includes obtaining, recording, or holding the data, organizing, amending, retrieving,

using, disclosing, erasing, or destroying it. Processing also includes transferring personal data

to third parties under privacy control conditions. Sensitive personal data includes contact info,

address, session activity on the platform, IP location etc. Sensitive personal data can only be

processed under strict conditions, and used for express purpose that it was collected for.

 

Data Protection Principles

Anyone processing personal data, must ensure that data is: Processed fairly, lawfully and in a

transparent manner. Collected for specified, explicit, and legitimate purposes and any further

processing is completed for a compatible purpose. Adequate, relevant and limited to what is

necessary for the intended purposes. Accurate and where necessary, kept up to date. Kept in

a form which permits identification for no longer than necessary for the intended purposes.

Processed in line with the individual’s rights and in a manner that ensures appropriate security

of the personal data, including protection against unauthorized or unlawful processing and

against accidental loss, destruction, or damage, using appropriate technical or organizational

measures. Not transferred to people or organizations situated in countries without adequate

protection and without firstly having advised the individual.

 

Fair and Lawful Processing

The Data Protection Requirements are not intended to prevent the processing of personal

data, but to ensure that it is done fairly and without adversely affecting the rights of the

individual. In accordance with the General Data Protection Regulation (GDPR), we will only

process personal data where it is required for a lawful purpose. The lawful purposes include

(amongst others): whether the individual has given their consent, the processing is necessary

for performing a contract with the individual, for compliance with a legal obligation, or for the

legitimate interest of the business. When sensitive personal data is being processed, additional

conditions must be met.

Collection of Information

We receive and store information about you such as:

Information you provide us: We collect information you provide to us which includes: your

name, email address, address or postal code, payment method, and telephone number. We

collect this information in a number of ways, including manual entry while you are using our

service, interact with our customer service, participate in surveys or marketing promotions,

provide reviews or ratings, taste preferences, set preferences in Your Profile/Account, or

otherwise provide information to us through our service or elsewhere.

Information we collect automatically:

We collect information regarding you and your use of our service, your interactions with us and

our advertising, as well as information regarding your computer or other device used to access

our service.

This information includes:

✓ Your activity on our platform such as course progress and search queries

✓ Details regarding your interactions with customer service such as the date, time and reason

for contacting us

✓ Transcripts of any chat conversations that you initiate on our platforms

✓ In the event that you initiate phone support, your phone number

✓ Device IDs or unique identifiers, device and software characteristics (such as type and

configuration)

✓ Connection information, statistics on page views, referral URLs, IP address, and standard

web log information

✓ Information collected via the use of cookies, web beacons and other technologies, including

ad data (such as information on impressions delivered to a cookie, the site URL where the

impression was delivered, as well as the date and time).

We use the information we collect to provide, analyze, administer, enhance, and personalize

our services and marketing efforts, to process your registration, your orders, your payments,

and your communication on these and other topics.

Our primary aim is always to enhance the user experience. We do so in several ways using

the data that we collect, but a few examples are: determining your general platform usage,

required action item completions, login details, etc. which then helps us know what difficulties

the you’re facing within the platform, with which can then use to take action to minimize the

effort on your end. We collect other information, such as most visited links on our website,

which then help us conclude what content was most watched, enabling us to create additional

content geared toward our users’ needs and personal preferences.

 

Processing for Limited Purposes

In the course of our business, we may collect and process personal data, which may include

data that we receive directly from a data subject and data we receive from other sources

including location data, business partners, and subcontractors who work technical, payment

and delivery services, credit reference agencies, and other capacities.

We will only process personal data for the specific purposes or for any other purposes

specifically permitted by the Data Protection Requirements. We will notify those purposes to

the data subject when we first collect the data or as soon as possible thereafter.

 

Notifying Individuals

If we collect personal data directly from an individual, we will inform them about:

The purpose or purposes for which we intend to process that personal data, as well as the

legal basis for the processing.

Where we rely upon the legitimate interests of the business to process personal data, the

legitimate interests pursued.

The types of third parties, if any, with which we will share or disclose that personal data.

The fact that the business intends to transfer personal data to a non-EEA country or

international organization and the appropriate and suitable safeguards in place.

How individuals can limit our use and disclosure of their personal data.

Information about the period that their information will be stored or the criteria used to

determine that period.

Their right to request from us as the controller access to and rectification or erasure of

personal data or restriction of processing.

Their right to object to processing and their right to data portability.

Their right to withdraw their consent at any time (if consent was given) without affecting the

lawfulness of the processing before the consent was withdrawn.

The right to lodge a complaint with the Information Commissioner’s Office.

Other sources where personal data regarding the individual originated from and whether it

came from publicly accessible sources.

Whether the provision of the personal data is a statutory or contractual requirement, or a

requirement necessary to enter into a contract, as well as whether the individual is obliged to

provide the personal data and any consequences of failure to provide the data.

The existence of automated decision-making, including profiling and meaningful information

about the logic involved, as well as the significance and the envisaged consequences of such

processing for the individual.

If we receive personal data about an individual from other sources, we will provide them with

this information as soon as possible (in addition to telling them about the categories of

personal data concerned) but at the latest within One (1) month. We will also inform data

subjects whose personal data we process, that we are the data controller with regard to that

data and our contact detail regarding data protection act is f mu dgl grw> ek _gj,amk

 

Adequate, Relevant and Non-Excessive Processing

We will only collect personal data to the extent that it is required for the specific purpose

notified to the data subject.

 

Accurate Data

We will ensure that personal data we hold is accurate and kept up to date. We will check the

accuracy of any personal data at the point of collection and at regular intervals afterwards. We

will take all reasonable steps to destroy or amend inaccurate or out-of-date data.

 

Timely Processing

We will not keep personal data longer than necessary for the purpose or purposes for which it

was collected. We will take all reasonable steps to destroy or erase from our systems, all data

which is no longer required.

 

Processing in line with Data Subject’s Rights

We will process all personal data in line with data subjects’ rights, in particular their right to:

Confirmation as to whether or not personal data concerning the individual is being processed.

✓ Request access to any data held about them by a data controller.

✓ Request rectification, erasure or restriction on processing of their personal data.

✓ Lodge a complaint with a supervisory authority.

✓ Data portability.

✓ Object to processing including for direct marketing.

✓ Not be subject to automated decision making including profiling in certain circumstances.

 

Data Security

We will take appropriate security measures against unlawful or unauthorized processing of

personal data and against the accidental or unlawful destruction, damage, loss, alteration, or

unauthorized disclosure of or access to personal data transmitted, stored, or otherwise

processed.

We will put in place procedures and technologies to maintain the security of all personal data

from the point of the determination of the means for processing and point of data collection to

the point of destruction. Personal data will only be transferred to a data processor if he or she

agrees to comply with those procedures and policies, or if he or she puts in place adequate

measures himself/herself.

We will maintain data security by protecting the confidentiality, integrity, and availability of the

personal data, defined as follows:

 

Confidentiality: Only people who are authorized to use the data can access it.

Integrity: Personal data should be accurate and suitable for the purpose for which it is

processed.

Availability: Authorized users should be able to access the data if they need it for authorized

purposes. Personal data should therefore be stored on the Howfinity central

computer system & databases instead of individual PCs.

 

Our Security Procedures:

Entry controls: Any stranger seen in entry-controlled areas will be reported.

Securing lockable desks and cupboards all the time. Desks and cupboards should be kept

locked if they hold confidential information of any kind. (Personal information is always

considered confidential.)

Data minimization will be practiced.

Pseudonymisation and encryption of data will be the primary state of storing the data.

Methods of disposal: Paper documents would be shredded. Digital storage devices would be

physically destroyed when they are no longer required. Electronic data would be deleted once

it’s intended purpose is fulfilled.

Equipment: Staff has to ensure that individual monitors do not show confidential information to

passers-by and that they log off from their PC when it is left unattended.

Transferring Personal Data Outside of the EEA: We may transfer any personal data we hold to

a country outside the European Economic Area (‘EEA’) or to an international organization,

provided that one of the following conditions applies:

The country to which the personal data is transferred ensures an adequate level of protection

for the data subjects’ rights and freedoms.

The data subject has given his consent.

The transfer is necessary for one of the reasons set out in the Act, including the performance

of a contract between us and the data subject, or to protect the vital interests of the data

subject.

The transfer is legally required on important public interest grounds or for the establishment,

exercise or defense of legal claims.

The transfer is authorized by the relevant data protection authority where we have adduced

adequate safeguards with respect to the protection of the data subjects’ privacy, their

fundamental rights and freedoms, and the exercise of their rights.

Subject to the requirements above, personal data we hold may also be processed by staff

operating outside the EEA who work for us or for one of our suppliers. Those staff may be

engaged in, among other things, the fulfillment of contracts with the data subject, the

processing of payment details and the provision of support services.

 

Disclosure and Sharing of Personal Data

We may share personal data we hold with any member of our group, which means our

subsidiaries, our ultimate holding company and its subsidiaries, as defined in: https://

www.legislation.gov.uk/ukpga/2006/46/section/1159

 

Subject Access Requests

To these ends, the company has a privacy statement setting out how data relating to

individuals is used by the company.

Individuals must make a formal request for information we hold about them. Employees who

receive a request should forward it to the data department immediately.

When receiving telephone enquiries, we will only disclose personal data we hold on our

systems if the following conditions are met:

We will check the caller’s identity to make sure that information is only given to a person who is

entitled to it.

We will suggest that the caller put their request in writing if we are not sure about the caller’s

identity and where their identity cannot be checked.

Where a request is made electronically, data will be provided electronically when possible.

Our support team will refer a request to the data processing department or the Data Protection

Compliance Manager for assistance in difficult situations.

 

Changes to this Policy

We may modify this Privacy Statement at any time, but we will provide prominent advance

notice of any material changes to this Statement, such as posting a notice through the

Services, on our websites, or sending you an email, to provide you the opportunity to review

the changes and choose whether to continue using the Services. For detailed information on

GDPR, please visit https://www.eugdpr.org/

 

Contact

If you have any questions regarding this policy, or your dealings with our website, please

contact us HERE.

Howfinity LLC (howfinity.com & howfinitycourse.com)

1500 N. Halsted St. Chicago, IL 60642

This document was updated January 1, 2020