Effective Date: December 1, 2017
 
Inner Compass Initiative is a 501(c)(3) charitable organization (“ICI” or “We”) whose mission is to provide information, resources, tools, and connecting platforms ​to facilitate more informed choices regarding all things "mental health" and to support individuals and groups around the world who ​wish to leave, bypass, or build community beyond the mental health system. ICI supports strong privacy protections and stands against the expansion of tracking and surveillance that is becoming characteristic of our society. With these values in mind, user interactions with our website are encrypted by SSL, we try to minimize the amount of information we collect and store, and we encourage users to employ supplemental methods to protect their privacy when interacting with our website. However, the technical nature and structure of the world wide web and the practices of the third party services with which we contract to operate our website inevitably put certain constraints on the privacy protections that we can provide to our users. Please read this Privacy Policy carefully – By visiting and using the website, you agree that your use of our website, and any dispute over privacy, is governed by this Privacy Policy. 


APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy describes the types of information that we collect through  (1) ICI’s website, www.theinnercompass.org (the “ICI Website”), (2) ICI Connect (collectively, the “Connect”), and (3) our related mobile and tablet applications (collectively, the “Applications”). It also describes how we store and manage that information. This Privacy Policy is an adjunct to our Terms and Conditions, and applies only to the information collected online through the Websites, the Connect, and the Applications, and does not apply to any information that you may provide to us or that we may collect offline and/or through other means (for example, at a live event, via telephone, or through the mail).


GENERAL RELEASE OF ALL CLAIMS

To the fullest extent permitted by applicable law, registered members of the Connect (“Members”), users of, and visitors to the Websites, the Connect, and/or the Applications release and waive any and all claims against ICI, its owners, agents, officers, shareholders, employees, directors, attorneys, subscribers, subsidiaries, affiliates, successors, and assigns, whether known or unknown, which allegedly arise from or relate to the intentional or accidental disclosure, whether by ICI, another Member, user or visitor, or an independent third party, of any information which the Member, user, or visitor voluntarily shared on the Websites, the Connect, and/or the Applications.

 
CHILDREN’S PRIVACY STATEMENT

Individuals under the age of eighteen (18) should always obtain permission from their parents before using or providing any personal identifying information (“PII”) about themselves including, but not limited to, their names, email addresses, and phone numbers, on the Websites. The Websites are not aimed toward providing information, resources, tools, and/or connecting platforms to children under the age of thirteen (13) and we do not knowingly permit anyone under the age of thirteen (13) to submit any PII through the Websites. If you are under the age of thirteen (13), please do not attempt to register for the Connects, use the Applications, or post comments on the Websites. If we become aware that we have inadvertently received PII from a child under the age of thirteen (13), we will delete such information from our records.

We screen all registrations for membership in the Connects to the best of our abilities and do not permit individuals under the age of eighteen (18) to join the Connects. 
 

COLLECTION OF INFORMATION

There are three categories of information that we collect: General User Information, Member Information and Donor Information.

General User Information

Many website owners employ “web analytics” programs to track and record various activities occurring on their websites. We may collect and store information other than PII that is generated automatically as you navigate through the Websites, review our newsletters, complete our online surveys, or otherwise engage with us online. For example, we may collect information about the devices you use to access the Websites, including the type of device you’re using (e.g., a computer, mobile phone, or tablet), the operating system running on that device, the type and version of browser software you’re using, the resolution of your computer monitor or other device display, the screen colors available on your device, and the website that referred you. We also use “cookies,” a standard feature found in browser software. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. We also may use web beacons (sometimes referred to as “clear GIFs”, “transparent GIFs”, or “pixel tags”) to collect non-personally identifying information about how our users use our website, communications, and content. We may also collect your IP address. This is a numerical address that is used by computers and other devices connected to the web to identify your device so that data such as the web pages that you want to view can be transmitted to you.

Member Information

You are not required to provide PII to access the Websites. However, if you wish to become a Member of the Connects and/or post comments on the Websites, then you may be asked to provide some or all of the types of PII described in this section. We collect and store information that you voluntarily supply to us when you register to become a Member of the Connects by creating a profile on the Website (“Member Profile”) and when you choose to send a direct message to another Member through the Websites (“Contact Message”). In registering for or using the Connects, you may voluntarily choose to provide some or all of the following types of information:

“Contact Information” – This is PII about you, such as your name and email address.
 
“Demographic Data" – This is information about you that does not specifically identify you, such as your gender, zip code, city or town, state or province, and country.
 
“Sensitive Personal Information” – This is any information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, health, lifestyle, past or present use of psychiatric medications, or other personal topics.
 
“Contact Messages” – This is the content of messages that are sent from one Member to another Member using the Connect Contact form.
 
“Comments and Posts” – This is the content of comments or posts that Members may post on the Websites, which may at times include PII if the Member chooses to provide such information in the comment.


Donor Information

If you donate money to ICI through the ICI Website donation portal, we may collect PII that you voluntarily provide, such as your name and contact information. (For more information on our donor platform, see “Relationships with Third Parties” in this Policy.)


USE, STORAGE, AND DELETION OF INFORMATION

General Web Use Information: We use the information collected by web analytics programs, cookies, and web beacons to help us understand how many unique users visit our site or various pages within our site, track user interests, trends and patterns, understand how users are interacting with our website or newsletter, improve our services, and deliver more relevant content to users. We may use IP address information for systems administration and troubleshooting purposes, to help us manage Members and Member comments, and to derive a rough estimate of your geographic location by country, city or town, and ZIP code. We regularly delete the details of our web analytics logs that are older than 90 days, and store thereafter only summary data.

PII: Except where otherwise noted during the Connect registration process, the PII that you provide in your Member Profile will be made visible to other Members of the respective Connect platform(s) of which you are a Member. This helps Members find and connect with each other based on their shared interests, backgrounds, experiences, and values. In addition, ICI may gather, analyze, and share certain anonymized, summary information from Member Profiles for research, education, or public awareness-raising purposes, such as total number of Members, number of Members who have experienced certain withdrawal symptoms after taking certain psychiatric drug types, or number of Members in a certain city interested in organizing events. You may change your own Member Profile information or delete your Member Profile at any time. The instructions for canceling your membership and deleting your account are provided on the homepages of ICI Connect.

Contact Information: ICI may use your Contact information to send you information about events, opportunities, changes, updates, and content of relevance to ICI, the Connects, and/or the information and preferences that you have shared with us. You may opt out of these communications by deleting your Member Profile and unsubscribing from our online newsletter service at any time.
 
Contact Messages: The storage and deletion of Contact Messages sent through the Connects is subject to the terms of service of our third-party transactional email provider: As of the date of this Privacy Policy, Contact Messages older than 30 days are automatically deleted except for summary data and metadata information and circumstances where a specific message generated a technical system error, was undeliverable, or bounced back. (For more information, see “Relationships with Third Parties” in this Policy.) ICI reserves the right to retain and review the content or metadata of Contact Messages as may become necessary to assist in the investigation and resolution of credible complaints about breaches of our Terms and Conditions, or as legally required by requests from law enforcement agencies.

Public Posts and Comments: In order to maintain the integrity of public discussion threads on the website (including within the Connects), we reserve the right to retain the content of public posts or comments even if a Member deletes their account. However, these public posts or comments will be attributed to the username "Anonymous." We discourage members from posting PII in comments or posts; however, if you reasonably believe that a specific comment or post previously posted by you or by another Member contains your PII and you do not wish for this PII to continue to be disclosed, we will, at your request, investigate and, where appropriate, remove the PII from the post or comment.

 
SECURITY OF PERSONAL INFORMATION
 
The security of your PII is extremely important to us. ICI has implemented and maintains reasonable security procedures and practices designed to protect against the unauthorized access, use, modification, destruction or disclosure of your PII. Despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against all forms of interception or other types of misuse. Both ICI and Members must do their parts to help ensure the security of data. Additionally, Members should secure their account by protecting it with a strong password.  Members should not disclose a password to any other person.
 
If you have reason to believe that your account or the PII we hold about you is not secure, please notify us at the address included in the Contact Us section below.
 
Although ICI makes reasonable efforts to prevent such occurrences, please be aware that anything you post on the website such as in Member Profiles, comment threads, chat areas, or message boards can potentially be seen, disclosed to, or collected by third parties beyond ICI’s control, and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As such, Members disclose any PII (including their email addresses, location, and/or names) at their own risk. We cannot be held responsible for any unauthorized third-party use of such information.
 

RELATIONSHIPS WITH THIRD PARTIES

ICI will never sell your Personal Information to third parties for any purposes and ICI will not share your Personal Information with third parties except as otherwise disclosed in this Privacy Policy. ICI reserves the right to disclose and use Non-Personal Information to those who help it provide services, including those who perform technical, administrative, and data processing tasks such as hosting, data storage, analytics, and security. ICI also reserves the right to share aggregated, anonymized information from Member Profiles with other selected third parties for the purposes of scientific research and/or public interest/educational purposes.

The potential privacy implications of the relationships of ICI to other third parties or third-party service providers are outlined below.

ICI Newsletter and Other Communications: Some of our Member and subscriber communications are handled through an ICI-managed account with MailChimp. When new users first register to become Members of the Connects, they are automatically subscribed to our newsletter and communications with MailChimp. In addition, any users may voluntarily subscribe to our newsletter and communications directly through our website. You are free to unsubscribe at any time by clicking the unsubscribe link in these communications. MailChimp collects your email address, username and real name (if you provided it) and uses them to send these communications. At the time of this writing, according to their Privacy Policy, MailChimp does not use this information for any other purposes.

Contact Messages: Contact Messages that you may send or receive as a Member of the Connects are delivered through Mandrill, a third-party transactional email service that was integrated with MailChimp in 2016. MailChimp/Mandrill stores a copy of each Contact Message within our MailChimp/Mandrill account for 30 days and ICI has access to these copies for that same period of 30 days. Bounced or undelivered messages are kept for 90 days, and certain metadata about all messages, such as date and time, are stored by MailChimp/Mandrill indefinitely. Note that the described MailChimp/Mandrill policies as of 2017 are not yet officially embodied in MailChimp’s publicly available Privacy Policy and will also be subject to change beyond our control. The most current version of MailChimp’s Privacy Policy can be found here.

Donations: We currently use GivingWise to manage online donations. The Privacy Policy of GivingWise can be found here.

Embedded links: On some pages within our website, we may link to or embed video, audio or other content from third parties including but not limited to YouTube, Vimeo, and SoundCloud. You should be aware that your interaction with this embedded or linked content may be tracked by these third-party services, and these interactions may be subject to the terms of service and privacy policies of these respective services beyond ICI’s knowledge or control.
 
Social Media: You may interact with our communications or content through social media services including but not limited to Facebook, Twitter, Google+, LinkedIn, and Pinterest. Again, you should be aware that we do not have full knowledge about or control of the information that these social media services may collect when you interact with our content on these services. You may wish to review the privacy policies of these respective third-party services prior to using them.
 
Web Analytics: ICI uses Matomo’s cloud-hosted analytics program to collect aggregate information on our audience and how our users interact with the Websites. The data gathered is accessible only by ICI-authorized administrators, and so the use and disclosure of this information is governed by this Privacy Policy.

Lawful Disclosure Requests: We may occasionally release information about our users or Members if required to do so by law or court order or if, in our judgment, such disclosure is reasonably necessary to comply with legal process, to enforce our Terms and Conditions, or to protect the rights, property, or personal safety of users of our website along with our board, employees, contractors, volunteers, or others. If we receive a request to disclose information that identifies you personally, and if we believe that it is our obligation under the law to comply with that request, if legally permitted to do so we will attempt to notify you of the request at the email address associated with your Member Profile with the comment that is the subject of the request. You may then challenge the request for disclosure of your PII if you wish to do so. If you do not promptly challenge the request and notify us that you have done so, if your challenge to the disclosure request is rejected, or if we deem it warranted under the circumstances, we may comply with the request. Additionally, if we believe it appropriate to do so under the circumstances, we will independently object to requests for access to information about Members of our website.

Transfer of Assets: In the unlikely event that we sell or transfer some or all of our assets, or our website is acquired by another non-profit organization or company, information about our user and Member information may be among the transferred assets.


REVISIONS AND MODIFICATIONS TO THIS POLICY

While every reasonable effort will be made to notify Members of any significant changes to our Privacy Policy, ICI reserves the right to revise this Policy without any obligation to notify past, current, or prospective users, subscribers, or Members of our website. If we need to change this Privacy Policy in the future, we will post the revised Privacy Policy on our Website with an updated “Effective Date” to reflect the date of the changes. You will be deemed to have agreed to any such modification or amendment by your decision to continue using the website following the date in which the modified or amended Privacy Policy is posted on the website. The use of information that we collect now is subject to the Privacy Policy in effect at the time such information is used.
 
 
CONTACT US

If you have additional questions about this Policy or concerns related to your Personal Information on our website, please write to us at hello@theinnercompass.org or at:

Inner Compass Initiative
P.O. Box 270158
West Hartford, CT 06107-9992
USA