PRIVACY POLICY

Your privacy is important to Johnson, Grossnickle and Associates (“JGA”). To better protect your privacy, we are providing this Privacy Policy to explain our online information practices and what choices you have about the way your information is collected and used. Please take a moment to familiarize yourself with our Privacy Policy to learn how we collect, use, disclose, transfer, store, and otherwise process your personal data, and to learn your rights and choices regarding your personal data.

Our Privacy Policy explains:

• About Us
• When These Privacy Principles and Practices Apply
• What Information Do We Collect?
• How We Use the Information We Collect
• How Do We Protect Your Information and Handle Data Retention?
• Do We Share Information with Outside Parties?
• Children
• Your Rights
• Changes to This Privacy Policy
• Contacting Us

A reference to “JGA,” “we,” or “us” is a reference to Johnson, Grossnickle and Associates and its relevant affiliates involved in the collection, use, sharing, or other processing of personal data. Please contact us if you have any questions – the “Contacting Us” section below lists our contact information and the contact information of our data protection officer.

1.  About Us

JGA is an Indiana-based consulting company that focuses on assisting nonprofit organizations. Our mission is to strengthen the field of philanthropy and assist in empowering nonprofit organizations to make the world a better place.

2.  When These Privacy Principles and Practices Apply

This Privacy Policy applies to information and data collected by JGA on our website (www.jgacounsel.com). For the avoidance of doubt, this online Privacy Policy applies only to information collected through our website and not to information collected offline or to the extent we process personal data in the role of a processor or service provider on behalf of our customers.

2.1 Personal Data

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you do not agree with the data practices described in this Privacy Policy, you should not use JGA’s website.

2.2  Third Party Links and Social Media Features

Our website may contain links to other websites maintained by third parties, social media features such as the Facebook Like button and widgets (such as the Share Button) which are either hosted by a third party or directly on our website, and/or mini-programs that run on our website. Third party websites and features may collect your personal data, such as you IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly.

Primarily, third party websites accessible through links on our website are governed by their own privacy policies. JGA does not control, and is not responsible for, the content or practices of these other websites. Our provision of a link does not constitute our endorsement of these other websites, their content, their owners, or their practices and this Privacy Policy does not apply to these other websites, which are subject to any privacy or other policies they may have.  We encourage you to be aware when you leave our website and to read the privacy statements of any other site that collects personal data.

This Privacy Policy also does not apply to social media features or mini-programs either hosted by a third party or directly on our website; instead, your interactions with such features, widgets, and/or mini-programs are governed by the privacy statements and policies of the companies providing them.

3.  What Information Do We Collect?

The categories of personal data we collect and have collected, including in the last 12 months, are as follows:

• Identifiers, including name, job title, company name, email address, mailing address, phone number, and IP address.
• Commercial information, including engagement with the website.
• Professional and employment-related information.
• Internet activity, including your interactions with our website and what led you to our website.
• Geolocation data provided through location enabled services such as WiFi and GPS.
• Inferences dawn from any of the above information categories, including information about your interests, preferences, and favorites.

3.1 Information You Provide Us

We collect information from you when you subscribe to our newsletter, respond to a survey, or fill out a form. For example:

• When you express an interest in obtaining additional information about our services, contact us (including by social media), participate in an online survey, register for an event or webinar, or download certain content, you may be asked to provide a variety of information including your name, mailing address, job title, company name, phone number, email address, demographic information, contact preferences, and profile information where the contact is made via social media.
• If you voluntarily submit certain information to our website, such as filling out a survey about your user experience, we collect the information you have provided as part of that request.
• If you post content to any JGA sponsored blogs or forums.

3.2 Information Automatically Collected

As is true of most websites, we gather certain information automatically if you visit, use, and/or interact with our website. For example, we may automatically collect certain information about your device and internet activity information, which may include identifiers, commercial information and internet activity information such as:

• internet domain information regarding the Internet service provider and/or mobile carrier through which you access the Internet;
• your browsing history, internet protocol (IP) addresses (or proxy server information), device and application information, or other identifiers of the computer you are using (such as, without limitation, identification numbers and features, location), which may qualify as personal data;
• your usage of our website (such as type of browser software and operating system you use, plug-ins, integrations, pages and files viewed, searches, operating system, system configuration information, date and time stamps associated with your usage, and frequency of visits to the websites and/or products), which may qualify as personal data;
• your profile information where the contact is via social media;
• your advertising and language preferences; and
• information on any referring website, application, or ad information such as the internet address of the website from which you linked directly to our site, if applicable.

This is common data collection information and helps us provide a better experience for you.

3.3  Information We May Receive About You

We may also collect information about you from third party sources, including third parties from whom we purchase personal data and from publicly available information. This helps us update, expand and analyze our records, identify new customers, and create more customized advertising. The personal data we collect from other sources may include identifiers, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. In particular, we may collect personal data from the following sources:

• Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles;
• Another individual at your organization who may provide us with your business contact information for the purposes of obtaining services; and
• Platforms such as HubSpot Analytics (an analytics service provided by HubSpot, Inc.) (“Hubspot”) and marketing services such as those provided by MultiView, Inc. to engage in marketing activities; and
• Other third party sources such as The Chronicle of Higher Education Inc. that may provide us with your personal information for marketing activities if you elect to download content sponsored by us on such third party’s website.

Some of this information may be in a form that does not, on its own, permit direct association with any specific individual or household. We may collect, use, transfer, and disclose non-personal data for any purpose. We also may combine this information with personal data provided by you; however, if we do combine non-personal data with personal data, the combined information will be treated as personal data for as long as it remains combined.

3.4  Cookies and Other Technologies

Additionally, we use cookies and other common information-gathering technologies, such as tools for collecting usage data, web beacons, tags, pixels, and JavaScript, to automatically collect information that may contain personal data as you navigate our website or interact with emails we have sent you. Whether used alone or in conjunction with each other, these technologies help us recognize you, understand and save your preferences for future visits and compile aggregate data about site traffic, site interaction so that we can offer better site experiences and services in the future. We treat information collected by cookies and other technologies as non-personal data; however, as noted above, to the extent that IP addresses or similar identifiers are considered personal data by applicable local law, we will treat these identifiers as personal data.

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers’ systems to recognize your browser and capture and remember certain information. When you visit our website, we, or an authorized third party, may place a cookie on your device that collects information (including personal data) about your online activities over time and across different sites. In some cases, cookies may remain on your device after you close your browser or turn off your device.

Cookies allow us to track and analyze site traffic, infer browsing preferences, and improve and customize your access and browsing experience. Our goals in these cases are to make your experience with JGA more convenient and personal, and to identify repeat visitors to our website. For example, knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize and enhance your experience on our website. Knowing your name and contact information prevents you from needing to enter it manually every time you complete a form on the site.

Cookies may also be used for market research or to display advertising that is not directed to a particular individual. We may use our own technology or third-party technology to track and analyze usage information for the purposes of providing enhanced interactions and more relevant communications, and to track performance of our advertisements. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google Analytics”). You can learn more about Google Analytics’s privacy practices by going to www.google.com/policies/privacy/partners. Google Analytics uses cookies to help us analyze how our website is used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. We use Google Analytics with restrictions on how Google can process our data enabled. This information is used by us to improve our website. Similarly, as noted above, we may also use Hubspot to assess analytics of our website and other marketing efforts by using both usage data and cookies. You can learn more about Hubspot’s privacy practices by going to https://legal.hubspot.com/privacy-policy. The third party services and/or technologies we use to help us collect information are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

We use both session-based and persistent cookies on our website. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off. Additional categories of cookies may include required cookies, functionality cookies, performance cookies, and targeting cookies, described as follows:

• Required cookies. Required cookies are necessary for basic website functionality, with some examples including session cookies needed to transmit the website and any authentication cookies. Because required cookies are essential to operate the website, there may not be an option to opt-out of these cookies.
• Functional cookies. These cookies enhance functions, performance, and services on the website. Some examples include cookies that allow our website to remember the choices you make and your account preferences, and to provide enhanced, more personal features. For example, these cookies will remember your name and other details so you don’t have to re-enter them when completing a form. You can choose to opt out of functional cookies.
• Performance cookies. These are analytics and research cookies that allow us to collect information about how visitors use our website, for instance which pages visitors go to most often, and if they get error messages from web pages. This helps us improve the way the website works and allows us to test different ideas on the site. You can choose to opt out of performance cookies.
• Targeting cookies. These cookies record your visit to the website, the pages you have visited and the links you have followed. We may use this information to make the website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. You can choose to opt out of targeting cookies.

We also use web beacons and pixels on our website and in emails. For example, we may place a pixel in marketing emails that enable us to send email messages in a format customers can read, and they tell us whether mail has been opened and/or if you click on a link in the email. We use these technologies to operate and improve our website and marketing emails. For instructions on how to unsubscribe from our marketing emails, please see the Note in Section 4 below.

Most browsers support cookies, but users can set their browsers to decline cookies and can delete them whenever they like. The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please keep in mind that without cookies, you may not have access to certain features of our website, including access to certain personalized content.

Further, your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site an app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.

4.  How Do We Use the Information We Collect?

We use the information we collect only in compliance with this Privacy Policy. More specifically, we collect and process personal data for a variety of purposes, including:

• Providing you with information about our company and service offerings, managing your registration for and attendance at our events and webinars, or otherwise communicating with you. In such instances, we may process your personal data, such as name and contact information, to the extent necessary for our legitimate interest in communicating with you and fulfilling your requests.
• To provide functionality through the website to improve, manage, and customize our website and services, and to identify customer opportunities based on the feedback we receive from you. We may process your device and usage data to the extent necessary for our legitimate interests in developing and improving our website and services, and providing our users with more relevant content and service offerings.
• Keeping you updated about, and if you elect to participate, administer your participation in, special events, webinars, programs, surveys, and other offers or promotions.
• To display personalized and other advertisements to you and periodically send you marketing communications about us, our services, and updates as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.

Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email and you may also opt-out by utilizing the information in the “Contacting Us” section below.

We only collect and process your personal data to the extent necessary to fulfill these purposes and where we can rely on a legal basis for such processing. Where required, we will ask you for your prior consent to processing.

5. How Do We Protect Your Information and Handle Data Retention?

5.1 Security

JGA takes the security of your personal data seriously. We implement a variety of security measures to help protect your personal data from unauthorized access, use or disclosure and secure the personal data you provide on computer servers in a controlled, secure environment. All personal data is protected using appropriate physical, technical, and organizational measures and only JGA personnel who have a need-to-know the information within the scope of performing their duties (for example, customer service) are granted access to such personal data.

However, when you post on a JGA forum or blog, the personal data and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal data you choose to share or submit in these instances. For example, if you list your name and email address in a blog posting, that information is public. Please take care when using these features.

5.2 Data Retention

We will retain your personal data for as long as you maintain an account or for a period of time consistent with the original purpose of collection (see the “How Do We Use the Information We Collect?” section above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for personal data on the basis of the amount, nature, and sensitivity of the personal data being processed, the potential risk of harm from unauthorized use or disclosure of the personal data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your personal data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

If you have questions about our data retention practices, please contact us by using the information in the “Contacting Us” section below.

6. Do We Share Information with Outside Parties?

We do not exchange, trade, or otherwise transfer your personal data to outside parties, whether public or private, without your consent. This, however, does not include trusted third parties who assist us in operating our website, conducting our business, or otherwise providing services to you. Further, we may share your personal data with trusted third parties if it is de-identified and shared in the aggregate. JGA will never sell your personal data to any third party.

6.1 Trusted Third Parties and Authorities

JGA uses a variety of third-party service providers to help us provide services related to the website, improve our services, or to help JGA market to consumers. For example, we may share your information with contracted third party service providers: (a) to perform website development, maintenance, and debugging; (b) to provide customer service and advertising; (c) to help us track website analytics, such as conversion and traffic metrics; (d) to verify information against public databases; (e) for data enrichment purposes; or (f) to investigate or respond to a complaint or security threat.

Examples of such third parties are Google Analytics as mentioned above for use in data analytics or external auditors or other related expert personnel who are hired by us to investigate or respond to a complaint or security threat. Further, if you use our website to register for an event or webinar organized by one of our affiliates, we may share your personal data with the affiliate to the extent required to process your registration and facilitate your participation in the event or webinar (although, in such instances, our affiliate will process your personal data as a controller and will provide you with further information on the processing of such data, where required). Additionally, if you attend an event or webinar organized by us, or download or access content on our website, we may share your personal data with sponsors of such event and, if you register to participate in a contest or promotion through our website, we may share your personal data with the applicable sponsor. If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business or assets are acquired by a third party, JGA may also share your personal data with such third party. In any of the foregoing events, we will only share your personally identifiable data with trusted third parties that agree to handle it in accordance with relevant laws and our contractual limitations as to their retention, use, and disclosure of such personal data.

JGA may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. In certain situations, we may also be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

6.2 De-identified and Aggregate Data

We may also share anonymous or de-identified usage data with third party service providers for the purpose of helping JGA in analysis and improvements, and further on an aggregate basis in the normal course of operating our business. For example, we may share information publicly to show trends about the general use of our services.

7. Children

Our website is not directed at children. We do not knowingly collect personal data from children under the age of 18. Please do not submit any information regarding individuals how are under the age of 18 and, if you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us by using the information in the “Contacting Us” section below and we will take steps to delete their personal data from our systems.

8. Your Personal Data Rights

8.1 Your Rights

You may have certain rights relating to your personal data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

• Access your personal data held by us: You have the right to request a copy of some or all of the information we have collected about you.
• Learn more about how we process your personal data, or to restrict or limit our use of your personal data.
• Correct, update or request deletion: You may contact us directly to manage your personal data or correct, update, or request deletion of any of your personal data (also called the right to be forgotten).
• Transfer your personal data to another controller, to the extent possible.
• Object, or withdraw your consent (where applicable), to any processing of your personal data carried out based on our legitimate interests.
• Opt-out: If you have consented to receive information from us, you can always opt-out or unsubscribe. While JGA does not sell personal data, you also have the right to opt-out of the sale of your personal data.
• Issue a complaint: You have the right to complain to a data protection authority about the collection and use of your personal data. For more information, please contact your local data protection authority.

JGA may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by applicable, local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described above.

If you choose to exercise your privacy rights, you have the right not to receive discriminatory treatment or a lesser degree of service from JGA.

8.2 How to Exercise Your Rights

To exercise your rights, please contact us by suing the information in the “Contacting Us” section below. We try to respond to all legitimate requests within forty-five (45) days and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.

8.3 Additional Disclosures for California Residents

The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell personal data. While JGA is not a business covered by the CCPA, we do not sell personal data. We may share personal data with third parties or allow them to collect personal data from our website as set forth in this Privacy Policy, or if you use JGA’s website to interact with third parties or direct us to disclose your personal data to third parties.

California law requires that we detail the categories of personal data we share or disclose for certain “business purposes,” such as disclosures to service providers that assist us with securing or marketing our services. We disclose such categories in section 3 above, entitled “What Information Do We Collect?” California law also grants state residents certain rights, including the rights to access specific types of personal data, to learn how we process personal data, to request deletion of personal data, and not to be denied goods or services for exercising these rights.

For information on how to exercise your rights, please refer to section 8.2 of this Privacy Policy.  If you are an authorized agent wishing to exercise rights on behalf of a California resident, please contact us using the information in the “Contacting Us” section below and provide us with a copy of the consumer’s written authorization designating you as their agent.

We may need to verify your identity and place of residence before completing your rights request.

9. Changes to This Privacy Policy

We will update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. Any change will be effective as of the date posted to our website, and we have no obligation to notify you of such changes.

This policy was last modified on February 21, 2020.

10.  Contacting Us

To exercise your rights regarding your personal data, or if you have any questions regarding this Privacy Policy or our privacy practices, please contact us using the information below: