Privacy Policy

Privacy Policy - Nefinc.org and NEF Mobile App

Last updated: March 26, 2024

Welcome and thank you for visiting our website located at www.NationalEquityFund.org (the “Website”) and/or using the NEF Mobile Application (the "App"); we appreciate your interest in our company. We take the protection of your personal information very seriously. This privacy policy provides comprehensive information relating to how we collect, use, and share your personal information at National Equity Fund, Inc. and the rights you have in relation to this data.

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”).

1.    Contact Information

National Equity Fund, Inc.

10 S. Riverside Plaza

Suite 1700

Chicago, IL 60606

Tel: (312) 360-0400

E-Mail: esimon@nefinc.org

2.    Geographic and other Restrictions

The owner of the Website is based in the State of Illinois in the United States. We provide this Website for use only by persons located in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. If you access the Website from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.

3.    Categories of personal information we collect

The data we process is determined by the context in question, e.g., it may vary depending on whether you have, e.g., submitted an inquiry via our contact form or otherwise.

Please note that we may also make information available separately to a suitable location for specific processing where appropriate, e.g. when uploading  documents or when submitting a contact request.

We obtain the categories of personal information listed below from the following categories of sources:

·        directly from you; for example, from forms you complete on our Website

·        indirectly from you; for example, from observing your actions on our Website

When you visit our Website, we collect and process the following data:

·        name of the Internet service provider

·        information on the Website you have visited us from

·        web browser and operating system used

·        the IP address assigned by your Internet service provider

·        requested files, amount of data transferred, downloads/file export

·        information on the pages of our Website(s) that you visit, including date and time

When you send us a “Contact Us” request, we collect and process the following data:

·        last name, first name

·        company name

·        title

·        contact data (email address and telephone number)

·        subject of your message

·        method of contact

·        details about your inquiry

When you use the App, we collect and process the following data:

 precise GPS location

 anonymized usage statistics

a    

We keep track of how you use and interact with our Website through the use of cookies and other tracking technologies as listed below. 

a.      Cookies

Our Website use what are known as cookies at multiple points. These are used to make our offering more user-friendly, effective and more secure. Cookies are small text files that are placed on your computer and stored by your browser (locally on your hard disk).

These cookies enable us to analyze how users use our Website. This means we can design the Website content according to our visitors’ needs.

We use both “session cookies” and permanent cookies. The session cookies are automatically deleted after your visit. Permanent cookies are automatically deleted from your computer when their expiry date is reached or when you delete them yourself before the expiry date.

Most web browsers accept cookies automatically. You can usually change your browser's settings if you would prefer not to send the information.

b.     Google Analytics

We use Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google uses cookies. The information generated by the cookie on the use of our content by the users are usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our Website and content by users, to compile reports on the activities within the Website  and to provide us with other services related to the use of our Website content and internet usage. In this case, pseudonymous usage profiles of the users may be created from the processed data.

We only use Google Analytics with activated IP anonymization. The full IP address is sent to a Google server in the US and shortened there. The IP address sent by the user's browser will not be merged with other data provided by Google.

Users may prevent the collection by Google of the data generated by the cookie and related to their use of the content and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

If your browser does not support the link to the Browser Add-On from Google (e.g. when using our Website from your smartphone), you can also opt out of data collection by Google Analytics by clicking on the link below. An opt-out cookie is then stored that prevents the future collection of your data when visiting this Website.

Click here to opt out of Google Analytics measurements.

c.      Precise GPS Location

When using the App, the user's location is obtained using the Device's GPS function, if permission is given. This data is used by the App only and is not transmitted to our servers or stored in any way. GPS location is used only for showing points of interest near the user.

4.    How we use your personal information

We may use or disclose the personal information we collect for one or more of the following purposes:

·        To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry.  

·        We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

5.    How we share your personal information

We will only share your data with third parties within the scope of the statutory provisions or with the appropriate consent. Otherwise, it will not be shared with third parties unless we are obliged to do so due to mandatory legal regulations (disclosure to external bodies such as law enforcement authorities in the United States).

a.      Within our organization

Within our organization, we ensure that only the individuals receive data who require that data to fulfill their contractual and legal obligations.

In many cases, our specialist departments are supported by Service Providers (defined below) to fulfill their tasks.

b.     With our Service Providers

We work with various organizations and individuals to help provide our services to you ("Service Providers"), such as Website and data hosting companies and companies providing analytics information. We need to engage such third-party Service Providers to help us operate, provide, and market our services. These third parties have only limited access to your information and may use your information only to perform these tasks on our behalf. Information we share with our Service Providers may include both information you provide to us and information we collect about you, including personal information and information from data collection tools like cookies.

We take reasonable steps to ensure that our Service Providers are obligated to reasonably protect your information on our behalf. If we become aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.

We share personal information with our Service Providers on the legal basis of our legitimate interests in providing you with our services. Our engagement of Service Providers is often necessary for us to provide the services to you, particularly where such companies play important roles like helping us keep our services operating and secure. In some other cases, these Service Providers aren’t strictly necessary for us to provide our services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our services better.

c.      To conduct business transactions

We may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets. Your information, including personal information, may be among assets sold or transferred as part of a business transaction. In some cases, we may choose to buy or sell assets. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our organization to develop over the long term.

d.     To respond to safety and lawful requests

We may be required to disclose your information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose user information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the services or using our name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this privacy policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

e.      Aggregated non-personal information

We may disclose aggregated, non-personal information received from providing the services, including information that does not identify any individual, without restriction. We may share demographic information with business partners, but it will be aggregated and de-personalized, so that personal information is not revealed.

6.    Your Rights and Choices

Effective on January 1, 2020, the California Consumer Privacy Act (CCPA) provides consumers (California residents) with specific rights regarding their personal information.  If you reside in California, you may exercise the following rights.

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a.      Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

b.     Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Otherwise make other internal and lawful uses of that information that are compatible with the context in which you provided it.

c.      Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

•       Calling us at 312-697-6449

•       Visiting www.nefinc.org

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

d.     Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time , we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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e.      Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”).  We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

[HYPERLINKED URL with the title “Do Not Sell My Personal Information”]

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:

[OPT-IN INSTRUCTIONS OR URL LINK]

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

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f.       Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7.    Data retention period

We store your data as long as it is necessary for the processing purpose in question. Please note that a number of legally imposed retention periods require data to be stored for extended periods. This relates in particular to commercial or fiscal retention obligations. Unless there are further retention requirements, the data will be routinely deleted after use.

In addition, we may retain the information if you have given us your permission to do so, or in the event of legal disputes and we use evidence within the statutory limitation periods.

8.    Links to other providers

Our Website also contains links to the websites of other companies. Where links to websites of other providers are available, we have no influence as to their content. As a result, no guarantee and liability can be assumed for this content. The content of these pages is always the responsibility of the respective provider or operator of the pages.

9.       Online offerings for children

We do not collect any information from children. Persons under the age of 16 are not permitted to submit any personal information to us without the consent of the legal guardian or a declaration of consent. We encourage parents and guardians to actively participate in the online activities and interests of their children.

10.   Changes to our privacy policy

We may modify this privacy policy from time to time. We will notify you of material changes to this policy by posting a notice at the Website or by emailing you at an email address associated with you, if applicable, and provide an “at a glance” overview of any changes.