Draft for ININ review. Not yet approved.

[This notice needs legal review before launch.] Text in highlighted square brackets is still to be confirmed by ININ.

How we use your information

This notice explains what information ININ Nexus collects about you, why we collect it, who can see it and the choices you have. We have tried to write it in plain language.

Last updated: [Effective date to be added once ININ approves this notice]

Who we are

ININ Nexus is run by Insight Nexus Integration Network (ININ) Inc., a Black-led non-profit organization in Newfoundland and Labrador. ININ Nexus is our website for events, forms, programs, learning and business tools.

When this notice says “we” or “us”, it means ININ.

Privacy contact: [Name or role of ININ’s privacy contact to be confirmed], [Privacy contact email to be confirmed]

What we collect

This is what ININ Nexus collects in its first release.

Your account

Your name and email address.
Your phone number, if you choose to give it.

Your consent choices

What you said yes or no to, when you said it, and which version of the wording you saw. See your consent choices.

Forms you send us

Your answers and email address when you register for an event, express interest in a program or apply to a program.

Event registrations and check-ins

Which events you registered for, whether you are registered or on a waitlist, and whether and when you checked in. The QR code on your ticket holds a random code only, not your name or other details.

Your business profile (optional)

If you choose to create one: your business name, sector, stage and city.

Saved pricing calculations

If you choose to save a calculation in our pricing tools, we keep the numbers you entered and the results.

Records we keep to run the service

A record of the emails we send you: your email address, the type of email and whether it was sent.
An audit log of important actions, such as changes to staff access, changes to the status of an application and event check-ins.
Cookies that keep you signed in. [Full list of cookies to be confirmed before launch]

Why we collect it

To create and run your account.
To register you for events and check you in.
To review your expression of interest or application for a program.
To contact you about things you have signed up for, and about other news only if you said yes to being contacted.
To save your business profile and calculations so you can come back to them.
To report totals to our funder, for example how many people attended an event.
To keep ININ Nexus secure and to find and fix problems.

We only use your information for research if you give separate consent. See research.

Who can see your information

You: You can see the information in your own account.
ININ staff: Staff see only what their role needs. For example, the staff who run a program can see the forms sent to that program. Only ININ’s administrator can give someone a staff role.
Facilitators: A facilitator sees names and attendance only for the sessions they run. They never see your application answers.
Partner organizations: Organizations that work with ININ never receive copies of participant data.
Our funder: The Atlantic Canada Opportunities Agency (ACOA) funds this work. ACOA sees totals only, such as the number of people who took part, and never individual records.
Business profiles and saved calculations: Only you can see your business profile and your saved calculations. ININ staff see them only as totals, for example how many people used a pricing tool.
Service providers: ININ Nexus runs on Supabase, a database and sign-in service, hosted in Canada. We send emails, such as event confirmations and your check-in code, through Resend, an email service in the United States: Resend receives your email address and the message we send you, so that information is handled outside Canada. When you send a form or create an account, a security check from Cloudflare, a web security service in the United States, makes sure the form is being sent by a person: during the check Cloudflare sees your IP address and signals from your browser (such as its type and settings), so that information is handled outside Canada. We use it to stop automated spam on our forms and sign-up. Before ININ uses any other service that handles your information outside Canada, we will name it here.

Research

ININ’s Black Entrepreneurship Research and Data Hub (BERDH) studies the experiences and needs of Black entrepreneurs so programs can improve. Learn more on our program pages.

Using your information for research needs its own, separate consent. Signing up for an event or program does not mean you have agreed to research.
Research uses de-identified data: your name, contact details and other details that could identify you are removed.
[ININ to confirm: saying no to research does not affect your place in a program]

We ask about three things separately. You can say yes to one and no to another.

Contact: Whether we may contact you with updates and news.
Research: Whether your de-identified information may be used for research.
Quotation: Whether we may quote things you tell us, for example in a report. [How quotes are credited, for example without your name, to be confirmed]

You can change any of these choices at any time. We keep a record of each choice and each change, so we can show what you agreed to and when.

How to change your choices: [Steps to change consent choices, in your account or by contacting us, to be confirmed]

Where your information is stored

Your information is stored in Canada.

How long we keep it

[Retention period to be confirmed by ININ]

Your rights

You can ask to:

See the information we hold about you.
Download a copy of it.
Correct it if it is wrong. You can change your name and phone number yourself in your account.
Delete it. [What, if anything, ININ must keep after deletion, such as totals already reported, to be confirmed]
Withdraw your consent for contact, research or quotation at any time.

To make a request, contact [Privacy contact email to be confirmed]. We will reply within [Response time to be confirmed by ININ].

How we protect your information

Access by role, checked by the database. Every record is locked by default. The database itself checks each person’s role before showing any record, so hiding a button is never the only protection.
Two-step sign-in for staff. ININ staff must use two-factor sign-in: a password plus a second check.
An audit log. Important actions, such as changes to staff access and data exports, are recorded in a log that staff cannot edit or delete.

Changes and questions

If we change this notice, we will update it on this page and change the date at the top. [How ININ will tell people about important changes to be confirmed]

Questions or concerns about your privacy? Contact [Privacy contact email to be confirmed].

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