This Privacy Policy was last updated on May 13, 2019

Grand River Solutions Inc. (“GRS”, “we”, “us” and/or “our”) operates this website and our platform of products and services to provide information about our company and our solutions to support higher education institutions and K-12 schools in providing effective, practical and sustainable responses to equity issues including Title IX, Title VII, VAWA and Clery compliance (altogether together, the “Services”).  This Privacy Policy sets forth our policy with regard to information including, personally identifiable data (“Personal Data”), that is collected from visitors to this website and through our Services.  We recognize that when you choose to provide us with personal data about yourself, you trust us to act in a responsible manner.

So we are clear about the terminology we are using, when we use the term “personal data” in this Privacy Policy, we mean any information relating to you as an identified person (such as your name, address, email address, telephone number, etc.).  When we use the term “anonymous information” in this Privacy Policy, we mean information that is not associated with or linked to your Personal Data.  Anonymous information does not enable identification of, or contact with, individual persons.

By voluntarily providing us with Personal Data through our Services, or by virtue of your assent to an “opt-in” request from us, you consent to our use of your Personal Data in accordance with this Privacy Policy.  If you provide Personal Data for the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to our offices and servers and the authorized third parties referred to herein located in the United States.

What information do we collect?

When you interact with our Services, we may collect Personal Data and other information from you, such as when you contact us with inquiries, register for access to Services, use certain Services, or allow third parties to provide us with information to contact you.  Here are some examples of Personal Data we may collect from you:

• We may collect your e-mail address and other Personal Data that you provide to us either in an email or if you contact us with a question or other inquiry.
• We may collect your name, address, phone number, e-mail address, and any other Personal Data that you provide to us if you contact us for employment;
• We may collect your name, address, phone number, e-mail address, company name and any other personal data that you provide to us through your registration or use of a Service or if you otherwise contact us regarding product or service information, sales inquiries, supplier inquiries, partner inquiries, or customer support/service inquiries.
• When you register for a Service or when you provide information in connection with a transaction, we may ask you for and collect certain Personal Data such as your name, e-mail address, shipping and billing addresses, telephone numbers, account number, user identification, and password.

The above list provides examples of the Personal Data that may be collected through our Services. In addition, we may collect your name, address, phone number, email address, and other Personal Data that you provide to us by completing a registration questionnaire or providing your business card to us at a trade show or other conference or meeting.

When you interact with us through our Services, we receive and store certain anonymous information. Such information, which is collected passively through various technologies, cannot presently be used to specifically identify you. We may store such information itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. We may use such anonymous information and pool it with other information to track, for example, the total number of visitors to a Service, or the number or visitors to a particular page of a Service, or the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

Use of Cookies

In operating our Services, we may use “cookies” (as defined below) and navigational data like Uniform Resource Locators (URLs) to gather information regarding the date and time of your visit and the information you viewed. “Cookies” are text files that are stored on your computer and that allow an analysis of the use you make of a Services. Most of the cookies that we use are deleted from your computer at the end of the browser session (so-called “session cookies”). Other cookies remain on your computer and allow us to recognize your computer on the next visit (so-called “persistent cookies”). These cookies may be used to greet you with your user name and to not require you to re enter certain information or fill out forms with your data for subsequent interactions. Cookies help provide additional functionality to the Services or help analyze usage of the Services more accurately. When we use cookies, we do not collect personal data except with your permission. If you do not want to use cookies, you may deactivate cookies in your web browser. Please be aware that disabling cookies might make it difficult to use some of our Service features, as some Service features may only be available with activated cookies.

We may also gather certain information automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data.

We may combine this automatically collected log information with other information we collect about you, including Personal Data, to improve our Services, as well as for marketing analytics and Service operation purposes.

Google Analytics

We may allow third party providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of, or engagement with, the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the website(s) associated with a Service and enhance your experience when you use our Services. The information generated by the cookie about your use of a website is usually transferred to a Google server in the US and stored there. However, if IP anonymization is enabled on a website located in the European Union (EU), Google may truncate your IP address beforehand within member states of the EU or other parties to the Agreement on the European Economic Area. Only in exceptional cases under this scenario will the full IP address be sent to a Google server in the US and shortened there.

On behalf of the operator of the website, Google will use this information to evaluate your use of the website, compile reports on website activity and provide other services related to website activity and Internet usage to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.

Such data collection and storage can be contested at any time with effect for the future. In addition, you may prevent the collection by Google of data generated by the cookie and related to your use of a Service (including your IP address) as well as the processing of this data by Google by using the following link (https://tools.google.com/dlpage/gaoptout?hl=en) to download and install the available browser plug-in.

For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
For more information about the Google Analytics Terms of Service, please visit: www.google.com/analytics/terms/.
The Privacy Policy for Google Analytics may be found at www.google.com/intl/en/analytics/privacyoverview.html.

How do we use information we collect?

We use the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the personal information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. If you provide Personal Data to obtain access to a Service, we may use your Personal Data to provide you with access to the Service, monitor your use of the Services, provide you with support, troubleshoot problems, resolve disputes, and communicate with you about the Services.

By way of further illustration, we and our affiliated companies may use your personal data and other personally non-identifiable or anonymous information collected through the Services to:

• deliver information, products or services you request or purchase;
• complete your transaction or service request;
• contact you in response to general e-mail inquiries and specific inquiries regarding our Services, employment, sales, suppliers, and support and service requests;
• provide Services through our platform and associated consulting, research and technical support;
• respond to your inquiries, investigate complaints, issue invoices and collect debts;
• monitor your compliance with the terms of our Services;
• help us improve the quality, content and functionality of our Services, and
• better understand our users and to improve the Services.

Personal Data provided to us for processing in conjunction with a Service, such as assisting with your compliance activities, is used only for providing the Service and for no other purpose.

We and our affiliates may use collected Personal Data to contact you in the future to tell you about information that we believe will be of interest to you, and to send you newsletters or other communications that you may have requested. If we do so, each marketing communication we send to you will contain an instruction permitting you to “opt-out” of receiving future marketing communications. If at any time you do not wish to receive any future marketing communications, please contact us as indicated below.

We may also use your Personal Data to create anonymous information records by excluding information that makes the information personally identifiable to you.

If you provide us with Personal Data, for instance when ordering products or information material, we treat the Personal Data in compliance with applicable law and regulations. To the extent these regulations allow the collection, processing or use of Personal Data without a separate formal consent for the processing of orders or inquiries, we will observe the applicable legal requirements and limits while obtaining formal consent where required. When registering for a newsletter, your email address will be used for the purpose of providing you with the newsletter until you unsubscribe. Opting-out of receiving our publications is possible at any time.

Our Disclosure of Your Information

We are not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are certain circumstances, however, in which we may share your Personal Data with certain third parties without further notice to you, as described below:

• We may provide your Personal Data to our vendors or other service providers to help us bring you the Services we offer or to facilitate our transactions with you. Specifically, we may share the Personal Data you have provided to us with vendors who house our servers, host our sites, for shipping and deliveries, to manage and service our data, distribute emails, conduct research and analysis, manage brand and product promotions, manage accounts, prepare invoices, send email updates about GRS and its products, remove repetitive information from our customer lists, process payments for products or services, and provide certain Services and features. Such third parties may have access to your Personal Data for use for a limited time in connection with these business activities. Where we utilize third parties for the processing of any Personal Data, we endeavor to implement reasonable contractual and technical protections limiting the use of that information to the purposes specified by GRS.
• We may disclose Personal Data to third parties to whom you ask us to send Personal Data.
• We may disclose your Personal Data if required to do so by law or in good faith belief that such action is necessary to: (i) comply with a legal obligation or government request; (ii) protect and defend the rights or property of GRS, including prevent illegal use of Services or violation of our Service terms and conditions or our policies; (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public; or (iv) protect against legal liability, defend against third party claims or assist in fraud prevention or investigation (such as counterfeiting).
• We may offer products or services jointly with other companies and we may share your information with that company in connection with your use of that product or service.
• As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.

GDPR Rights

For purposes of the EU General Data Protection Regulation and if you are an EU data subject, or under certain other national or state laws, you have the right to request: (i) access to your Personal Data; (ii) correction of your Personal Data if it is incomplete or inaccurate; (iii) deletion of your Personal Data; and (iv) object to the processing of your Personal Data on compelling legitimate grounds relating to your personal situation. Where we have obtained your consent for the processing of your Personal Data, you have the right to withdraw your consent at any time. You also have the right to object to the processing of your Personal Data, including opting-out from the use of such information for direct marketing purposes.

Exclusions

This Privacy Policy does not apply to any unsolicited information you provide to us through a Service or any other means. All such unsolicited information will be deemed non-confidential and we are free to reproduce, use, disclose, and distribute any such unsolicited information to others without limitation or attribution.

Children

We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Services, please contact us, and we will endeavor to delete the information from our databases.

Links to Other Websites

This Privacy Policy applies only to our Services. Our Services may contain links to other web sites not operated or controlled by GRS (the “Third Party Sites”). The policies and procedures we describe here do not apply to the Third Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Online Tracking

Certain pages on our website may have software or lines of code installed within the page that provide us with information about the “clickstream” of our visitors during their visit to our Service. This also allows us to know which pages the visitors came from, what navigational paths they took, and which areas of the site they visited. We currently do not respond to Do Not Track (“DNT”) signals.

Security Measures

GRS takes reasonable steps to protect Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, including a variety of technical and organizational security measures to maintain the safety of your Personal Data. We also use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction and your Personal Data is processed in secured networks and is only accessible by a limited number of persons with access rights to these systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. No Internet or email transmission is ever fully secure or error free and our Services may not be secure. Please keep this in mind when disclosing any Personal Data to GRS via the Internet and we will have no liability for disclosure of such data due to errors in transmission or interception by unauthorized acts of third parties.

We retain your personal data for as long as necessary to fulfill the purposes for which we collect it, except if required otherwise by law.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Service or providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to the Services. We may post a notice on a Service if a security breach occurs. We may also send an e-mail to you at the e-mail address you provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

Other Terms and Conditions

Your access to and use of the Services is subject to the applicable terms and conditions for the respective Service.

Changes to the GRS Privacy Policy

The Services, our business, and applicable law and regulations may change from time to time. As a result, at times it may be necessary or appropriate for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically and especially before you provide Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy will indicate your agreement with the terms of such revised Privacy Policy.

Control and Access to Information

To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data that you have previously submitted via the Services. Upon your request, we will close your account and terminate your participation in Services. We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce applicable terms or agreements, for archival purposes, and take other actions otherwise permitted by law.

Contacting GRS

You may object to the processing of your Personal Data and withdraw your consent (with effect for the future) at any time. For any questions about data privacy, or to issue an objection or withdraw your consent, please contact privacy@grandriversolutions.com.  Additional contact information is available at: https://grandriversolutions.com.