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
gather from you. By using this website, you consent to the terms described in the most recent
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
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
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 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
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/
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
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
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
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
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
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.
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
• Redistribute any content from our website, including onto another website.
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
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
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
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.
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.
Howfinity reserves the right to modify this statement at any time. Any changes to
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
✓ 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.
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
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
✓ Connection information, statistics on page views, referral URLs, IP address, and standard
web log information
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.
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.
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.
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.
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
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
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
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
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
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://
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/
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