Privacy Policy

Who we are

Our website address is: http://towernorth.com.

Tower North, on behalf of itself and its subsidiaries, (collectively, “TowerNorth”, “we, “us”) is fully committed to protecting the personal information of our users and using it properly. We will not release Personal Data about you to third parties for purposes other than to provide services to which you have agreed, or to comply with legal requirements. We are committed to upholding best practices in our use, collection, storage and disclosure of personal information. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.

 We strongly urge you read this policy and make sure you fully understand and agree with it, before you access or use any of our services. By accessing or using this Website you accept these Terms of Use and we agree to abide by the Privacy Policy stated below. If you are unwilling to accept these Terms please exit our Website immediately.

YOUR CONSENT – PLEASE READ CAREFULLY
This Tower North Privacy Policy (“Privacy Policy”) describes how we may collect and use information pertaining to each of our visitors (“Visitor”, “Prospect”, “Client” or “you”) in connection with their access to and use of websites, web applications (“Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”).

 This Privacy Policy constitutes a binding and enforceable legal contract between Tower North and you – please read it carefully.

 You may visit and/or use the Services only if you fully agree to this Privacy Policy – and by accessing and/or using any of the Services, you signify and affirm your informed consent to this Privacy Policy, including to the collection and processing of your Personal Information as defined and explained below.

 Please note: you are not obligated by law to provide us with any information. You hereby acknowledge, warrant and agree that any information you do provide us is provided of your own free will and consent, for the purposes and uses described herein.

GENERAL DATA PROTECTION REGULATION (GDPR)
The US Department of Commerce has agreed on requirements that permit U.S. companies to satisfy the mandate under European law and Swiss law that adequate protection is provided to Personal Data transferred from the European Union, European Economic Area, or Switzerland to the U.S. For EU citizens’ personal data, these requirements are memorialized in the EU-US Privacy Shield Framework. For Swiss citizens’ Personal Data, these requirements are memorialized in the Swiss-U.S. Privacy Shield Framework.

This EU Personal Data Privacy Policy (the “Privacy Policy”) sets forth the privacy principles that we follow with respect to Personal Data transferred from the European Union member countries and Switzerland to the United States of America.

Tower North is 100% committed to data protection. That’s why we welcome the General Data Protection Regulation (also known as the GDPR), which was recently approved and adopted by the European Union (EU).

What is the GDPR?

The GDPR is a regulation intended to strengthen and unify data protection for all individuals within the European Union (EU). It aims to protect the fundamental right to privacy and the protection of personal data.

WHAT INFORMATION DO WE COLLECT?
Visitor and User Information

We collect two types of information regarding our Visitors, Clients and Prospects:

Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-Personal Information”). Such Non-personal Information does not enable us to identify the Visitor, Client or Prospect from whom it was collected. The Non-Personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’, Clients’ or Prospects’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s, Client’s or Prospect’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third-party accounts (such as the e-mail or username for a connected Instagram, LinkedIn, Google or Facebook account), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors, Clients and/or Prospects through their access to and/or use of the Services. For the avoidance of doubt, any Non-Personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.

HOW DO WE COLLECT SUCH INFORMATION?
There are two main methods we use:

We collect information through your use of the Services. In other words, when you are visiting or using our Services, including when you browse the Website or upload information and content, view and/or download videos and/or webinars, and/or download any Tower North forms, documents or brochures, we are aware of it any may gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed below, including through the use of “cookies” and other tracking technologies, as further detailed below.
We collect information that you provide us voluntarily. For example, we collect the Personal Information you provide us when you fill out Tower North’s Info inquiries to receive further information about our Services; when you fill out a contact form to download our brochures or other documents requiring your information to download Tower North information directly from our website; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly.

WHY DO WE COLLECT SUCH INFORMATION ?
We collect such Non-Personal and Personal Information for the following purposes:

To provide and operate the Services;
To further develop, customize and improve our Services, based on users’ common or personal preferences, experiences and difficulties;
To be able to contact our visitors with general or personalized information, notices and promotional messages (as further detailed below);
To facilitate, promote and inform certain events, press releases and product information; determine visitors’ interest, monitor performance and contact qualified leads;
To enhance our data security and fraud prevention capabilities and
To comply with any applicable laws and regulations.

WHERE DO WE STORE YOUR INFORMATION?
Tower North’s Visitors’, Prospects’ and Clients’ Personal Information may be maintained, processed and stored by Tower North and our authorized affiliates in the United States of America, in Europe and in other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.

Tower North Consulting Group, Inc. is based in the United States of America with services offered in Europe, which is considered by the European Commission to be offering an adequate level of protection for the personal information of EU Member State residents.

Upon request Tower North will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us and we will respond to your request within a reasonable timeframe.

Data Localization Obligations: If you reside in a jurisdiction that imposes “data localization” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and we become aware of that, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so. 

You acknowledge and agree that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America as explained above.

SHARING PERSONAL INFORMATION WITH THIRD PARTIES
Tower North may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:

Third Party Services: Tower North has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”). 

Such Third Party Services may receive or otherwise have access to our Visitors’, Prospects’ and Clients’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Note that while our Services may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices, and encourage you to be aware when you leave our Services and read the privacy statements of each and every website and service you visit. This Privacy Policy does not apply to such linked third-party websites and services.

Law Enforcement, Legal Requests and Duties: Tower North may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.

Protecting Rights and Safety:Tower North may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of Tower North, any of our Clients, Service Providers, or any member of the general public, with or without notice to you.

Social Media Features and Framed Pages: Our Services include certain Social Media features and widgets, such as LinkedIn, Twitter , Vimeo and YouTube connect buttons, the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties are governed by their policies and not ours.

USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
Tower North, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors with a better experience, to better secure our Services, to identify needs, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.

Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services may have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy and we do not have any control over them.

Cookies:  In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.

If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by G-CON, and we therefore cannot ensure its accuracy, completeness or availability). Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services or may otherwise adversely affect your user experience.

Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies.

User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you.  This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.  If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

COMMUNICATIONS FROM TOWER NORTH
Promotional Messages: By subscribing to any Services (including to any of our newsletters, blogs, social media accounts or public events) and providing Tower North with your e-mail address or any other contact information (such as your phone number or social media handle), you expressly agree to receive promotional content, messages or calls from Tower North or our representatives through such means.

ACCESSING YOUR PERSONAL INFORMATION
If you wish to access and/or request us to make corrections to the Personal Information that you have stored with us, or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, contact us.

DATA RETENTION
We may retain your Personal Information for as long as needed to provide you with our Services. We may continue to retain such Personal Information even after you decide to move forward with our services and/or cease to use any particular website Service, as reasonably necessary to comply with our legal obligations prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

SECURITY
Tower North has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. We regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and users’ privacy.

However – regardless of the measures and efforts taken by Tower North, we cannot and do not guarantee the absolute protection and security of your Personal Information, or any other content you upload, publish or otherwise share with Tower North or anyone else.

We therefore encourage you to avoid providing us with any sensitive information the disclosure of which could cause you substantial or irreparable harm. Furthermore, because certain areas on our Services are less secure than others and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.

If you have any questions regarding the security of our Services, please contact us.

TERMS OF USE, UPDATES AND INTERPRETATION
Your use of any of our Services, and any disputes arising from it, is subject to this Privacy Policy as well as our Terms of Use and all of its general provisions including disclaimer of warranty, limitation of liability and indemnity.

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by, construed under and enforced in all respects solely and exclusively in accordance with the internal substantive laws of the state of Delaware in the United States of America, without respect to its conflict of laws principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being decided exclusively by, a court of competent jurisdiction located in New Castle County, DE USA.  

We may update this Privacy Policy to reflect changes to our information collection, usage and storage practices. Tower North may revise this Privacy Policy & Terms of Use at any time. Revisions will be posted on the Website and users are responsible for reviewing this page periodically. Except if and as stated otherwise, our most current Privacy Policy applies to all information that we have about you, with respect to our Website and other Services.

Any heading, caption or section title contained herein is provided only for convenience, and in no way defines or explains any section or provision hereof, or legally binds any of us in any way.

This Privacy Policy was written in English, and may be translated into other languages for your convenience. You may access and view other language versions by changing your Website language settings. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.