The Nantucket Project, LLC Privacy Policy

The Nantucket Project, LLC (“TNP”) takes your privacy very seriously. Please read this Privacy Policy (“Policy”) carefully as it contains important information on how and why we collect, store, use, and share information that relates to you and may identify you as an individual (“Personal Information”). This Policy also explains your rights in relation to your Personal Information and how to contact us or supervisory authorities in the event you have a complaint.

By using the Services, you accept the privacy practices contained in this Policy. If you do not agree to this Policy, do not use the website, associated Services, or submit Personal Information to us in any manner.

1. Who We Are and What We Do
The Nantucket Project, LLC is a Delaware limited liability company with our headquarters in Greenwich, Connecticut. We provide software and services, including the TNP website located at www.tnp.us, The Neighborhood Project, and associated mobile applications (collectively, “Services”). We also partner with third parties who help further our mission and support our events (“Partners”).

2. The Personal Information We Collect and Use

(a) Source(s) of Personal Data Collected by Us

We collect information about you (i) When you provide it to us or our Service Providers (defined below), (ii) with automated technologies, and (iii) from third parties.

(i) Information You Provide to Us

We collect Personal Information that you provide to us and our Service Providers.
Voluntary submissions can occur when you purchase subscription services, use the Services, make content submissions, make suggestions, or participate in online interactive activities.

(ii) Information We Collect Automatically

Some information, such as IP address and/or browser and device characteristics, is automatically collected when you visit our website and Services. This Personal Information is required to provide Services to you. If you do not provide the Personal Information we ask for, it may delay or prevent us from providing Services to you.

(iii) Information Collected from Third Parties and Other Sources

We may use analytics service providers to analyze how you interact and engage with the Services. Third parties may help us provide you with customer support or payment processing. We also obtain Personal Information from other sources, such as our Partners, and may collect from authorized resellers of our products. We obtain such information only in relation to the Services and products we provide.

(b) How We Use Your Personal Information

TNP does not sell your personal data to third parties. Any Personal Information that you supply to us remains your personal property. However, by submitting that information to us or our Services and accepting the terms of this Privacy Policy, you grant us the right to use your Personal Information for the following purposes:

  • To deliver the Services you have purchased or requested
  • To help us better understand visitors use of the website
  • To respond to specific requests from visitors
  • For business purposes such as improving products, services, marketing, and user experience
  • To protect the security or integrity of the website
  • To create and manage user accounts
  • To send marketing and promotional communications
  • To send administrative information
  • To enable user-to-user communications
  • To enforce terms and conditions and policies

(c) Who We Share Your Personal Information With

For the purposes of delivering the Services to you we share information with:

  • Service providers, such as web hosting services, software and service providers, payment service providers, warehouses, and delivery companies (“Service Providers”)
  • Other third parties we use to help us provide the Services and run our business, including but not limited to marketing agencies, analytics providers, and e-mail service providers (“Other Third Parties”)
  • Third parties provided and or approved by you
  • We reserve the right to disclose Personal Information to respond to information requests from government authorities, to address national security situations, to protect your rights, to fulfill business obligations, or when otherwise required by law, in our sole discretion.

(d) Reasons We Collect and Use Your Personal Information

We collect and use your Personal Information to further the following legitimate interests: to send e-mails, fulfill orders, deliver Services and products, complete customer transactions, improve website performance and provide customer service.

(e) Whether Information Has to Be Provided by You and Why

The provision of name, e-mail, address, phone number, credit card information and/or other billing information is required from you to enable us to process and complete your order for the Services. We do not require you to provide any personal data in order to browse on the website. We will inform you when we collect it whether you are required to provide the information to us.

(f) How Long Your Personal Information Will Be Kept

We will keep your Personal Information while you have an account with us or while we or our partners are providing products and Services to you. Thereafter, we will keep your Personal Information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf
  • To show that we treated you fairly
  • To keep records required by law

We will not retain your Personal Information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of Personal Information. When it is no longer necessary to retain your Personal Information, we will delete or anonymize it.

(g) Summary of Information We Collect and Who We Share It With

Categories of Personal Information Specific Types of Personal Information Collected Source(s) of Personal Data Categories of Third Parties With Whom We Share this Personal Data for a Business Purpose:
Voluntary Contact Submission. We collect voluntary submissions when you submit information or content to us, subscribe to one of our mailing lists, make suggestions, participate in online activities, or register for events or contests.
  • Name
  • Postal Address
  • E-mail Address
  • Other information in order to subscribe to one of our mailing lists
You
  • Partners
  • Service Providers
  • Other Third Parties
  • Authorized information requests
Customer Account Information. To use certain features of the Services, you must create an account and provide a username, password, and e-mail address. We may store your user account preferences and settings including:
  • Name
  • Postal Address
  • E-mail Address
  • Phone numbers
  • Credit card information
You
  • Partners
  • Service providers
  • Other Third Parties
  • Authorized information requests
Content You Submit. We collect certain content you submit to the Services including but not limited to text, links, images, gifs, and videos and general input (e.g., feedback you provide us about our Services or other information you voluntarily submit).

You may contribute posts on your timeline and comments on other people’s timelines (including saved drafts). We collect and display this information.

During film screenings and live discussions, you may participate inaudio and/or audiovisual interactions with other users and submit written comments. We do not collect these.
You
  • Partners
  • Service providers
  • Other Third Parties
  • Authorized information requests
Actions You Take. We collect information about the actions you take when using the Services. Collected actions may include text, links, images, numeric data, gifs, and videos. This may include:
  • Interactions with content.
  • Interactions with other users.
  • Posts and comments including saved drafts
  • Your messages with other users
  • Your reports and other communications with us.
You
  • Partners
  • Service providers
  • Other Third Parties
  • Authorized information requests
Transactional Information. Payments are processed by third-party payment processors (e.g., Stripe), so please refer to the applicable processor’s terms and privacy policy for more information about how payment information is processed and stored. Third Party
  • Partners
  • Service providers
  • Other Third Parties
  • Authorized information requests
Other Information. You may choose to provide other information directly to us. We may collect information when you fill out a form, participate in sponsored activities or promotions, apply for a job, request customer support, or otherwise communicate with us. You
  • Partners
  • Service providers
  • Other Third Parties
  • Authorized information requests
General Browsing In addition to information that you choose to submit, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site(s) or use Services (“Usage Information”).

This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site(s) or Services. Usage Information may include:
  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier (“Device Identifier”).
  • Your Device functionality (including browser, browser language, operating system, hardware, mobile network information).
  • Referring and exit web pages and URLs.
  • The areas within our Site(s) that you visit and your activities there, including remembering you and your preferences.
  • Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services.
  • Your Device characteristics; and
  • Certain other Device data, including the time of day you visit our Site(s).
Automatic
  • Partners
  • Service providers
  • Other Third Parties
  • Authorized information requests
Cookies and Similar Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device.

A few of the Tracking Technologies used on the Site(s), include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

  • Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.
  • Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
  • Pixels. A tiny image that may be found within web pages and e-mails, requiring a call (which provides device and visit information) to our servers in order for the pixel to be rendered in those web pages and e-mails.
  • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
  • ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
  • Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
  • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
Automatic
  • Partners
  • Service providers
  • Other Third Parties
  • Authorized information requests
Your Device and Location
  • When you visit or leave our Services, we may receive the URL, Plugins, and Cookies, of both the site you came from and the one you go to and the time of your visit.
  • Information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier).

    If you use our Services from a mobile device, that device may send us data about your location based on your phone settings.
Automatic
  • Partners
  • Service providers
  • Other Third Parties
  • Authorized information requests

3. Children’s Privacy

Consistent with the Children's Children’s Online Privacy Protection Act, The Nantucket Project is committed to protecting children's children’s privacy on the Internet. By browsing and or utilizing The Nantucket Project Services you certify that you are age 16 or above and agree to be bound by the Site’s Terms of Use.

The Services are not designed to attract anyone under the age of 16 and are not intended for use by any children. We do not knowingly collect any Personal Information from visitors or users of our site who are under the age of 16.

If you have reason to believe that a child under the age of 16 has provided Personal Information to us, please contact us using the information listed in the section entitled “Contact Us”, and we will endeavor to delete that information from our databases. Children under the age 16 are not allowed to create an account or otherwise use the Services.

4. Change in Control or Sale

We can share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us, or part of our business, will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5. International Data Transfers

We are based in the United States and we process and store information on servers located in the United States. We may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law.

6. Do Not Track Requests

We take action in response to Do Not Track (“DNT”) signals.

Many web browsers give you the option to send a DNT signal to the websites you visit, indicating that you do not wish to be tracked. There is no accepted standard for how a website should respond to this signal, and we disable cookies in response to this signal. Please note that if you remove or chose not to accept our cookies, some features of our services may no longer function and you will need to reenter your information and reselect your preferences each time you visit our Services.

7. Links to Other Sites

Our website may contain links to websites operated by others. You may see advertising or other content on this website or our Services that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, or other third parties. Any products or services reached through a third-party link are subject to its own separate privacy policies. We are not responsible for or liable for any content on or actions taken by such third-party websites.

8. Keeping Your Personal Information Secure.

We undertake reasonable efforts to ensure that Personal Information is protected while you are utilizing our Services. All information collected from you is stored in a technically and physically secure environment. Furthermore, Service Providers, Partners, employees, contractors, and vendors who have access to your personally identifiable information in connection with providing Services for us are required to keep the information confidential. Our team is dedicated to ensuring the security and privacy of all user information.

We utilize SSL web encryption, data, and password encryption to protect sensitive information online, and we do everything we can to protect user information offline. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk.

9. Your Choices

If you want to unsubscribe from receiving e-mails from us, you may do so at any time. Each e-mail includes instructions for unsubscribing from these e-mail communications.

10. Your Rights Under the California Consumer Privacy Act (“CCPA”)

If you are a California resident, you may review, change, or terminate your account at any time.

Disclosure of Personal Information We Collect About You You have the right to know:
  • The categories of Personal Information we have collected about you;
  • The categories of sources from which the Personal Information is collected;
  • Our business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information, if any; and
  • The specific pieces of Personal Information we have collected about you.
Please note that we are not required to:
  • Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
Provide the Personal Information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and The categories of Personal Information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale (or disclosure) of your Personal Information. If you exercise your right to opt-out of the sale (or disclosure) of your Personal Information, we will refrain from selling your Personal Information, unless you subsequently provide express authorization for the sale of your Personal Information.

To opt-out of the sale or disclosure of your Personal Information, please contact us via the “Contact Us” section of this Policy
Right to Deletion Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
  • Delete your Personal Information from our records; and
  • Direct any service providers to delete your Personal Information from their records.
Please note that we may not delete your Personal Information if it is necessary to:
  • Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 you and us;
  • 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;
  • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  • Please note that we may charge a different price or rate or provide a different level or quality of goods or the Services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

You may make a written request to us utilizing the information in the “Contact Us” section of this Policy to request this information. We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request twice a year.

11. Your Rights Under the General Data Protection Regulation (“GDPR”).

If you are a citizen of the European Union, or United Kingdom you may review, change, or terminate your account at any time and have the following rights:

Right to Access The right to be provided with a copy of your Personal Information (the right of access)
Right to Rectification The right to require us to correct any mistakes in your Personal Information
Right to be Forgotten The right to require us to delete your Personal Information—in certain situations
Right to Restriction of Processing The right to require us to restrict processing of your Personal Information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object The right to object:

  • at any time to your Personal Information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
Right to lodge a Complaint with a Supervisory Authority The right to lodge a complaint in the European Economic Area state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authorities may be accessed through the European Commission here.

You may make a written request to us regarding the above rights utilizing the information in the “Contact Us” section of this Policy.

12. Your Nevada Privacy Rights – Privacy Notice for Nevada Residents

If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your Personal Information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or Services for personal, family, or household purposes from us, you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, e-mail address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).

As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing utilizing the information in the “Contact Us” section of this Policy with “Nevada Privacy Rights” in the subject line. You must include your full name, e-mail address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out. (you must complete a separate request for each service.)

We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond.

13. Terms of Service

Please read the Terms of Service Policy carefully to understand other terms and conditions that govern your use of this Website and Services. This Privacy Policy is incorporated in the Terms of Service Policy.

14. Revisions and Updates

This privacy notice was published on September 10, 2020 and last updated on September 10, 2020. The Privacy Policy may be revised from time to time, in which case the Privacy Policy you view will be the most current version and the date of the latest such revision will be identified at the beginning of this Privacy Policy. We will inform you of any substantial changes via updates to this page and via e-mail.

15. How to Contact Us
(a) General Questions and Technical Support

If you need technical support or want to report a bug involving the Services, please contact us at info@nantucketproject.com.

(b) Please direct all communications concerning this Policy to our Privacy Team: The Nantucket Project, 123 Mason Street, Greenwich, CT, 06830 at info@nantucketproject.com.
  • In all communications with us, please include the e-mail address used for a subscription, the website address or the specific program to which you provided Personal Information and a detailed explanation of your request.
  • If you would like to delete or amend your Personal Information and are contacting us by e-mail, please put “Deletion Request” or “Amendment Request”, as applicable, in the subject line of the correspondence. We will do our best to respond to all reasonable requests in a timely manner.
(c) Your rights under the GDPR, CCPA, and Other Applicable Laws.
  • Request to Export Data: If you wish to request that we export your data from our database so you can port it to another vendor, please send an e-mail to info@nantucketproject.com or contact the Privacy Team with the subject line “Export My Data”, and explain in the body of the e-mail that you are asking for a data export.
  • Request to Forget: If you wish to request that we “Forget you” from our database, please send an e-mail to info@nantucketproject.com or contact the Privacy Team with the subject line “Forget Me”, and explain in the body of the e-mail that you are asking to have all of your data deleted.

We have a standard data export format that we will provide and are not able to create custom exports. To protect user privacy, you must send such a request from the account information we have on file or the request will not be honored.