Privacy Policy

Thank you for visiting BlackNorth BEGIN.

BlackNorth BEGIN (the “Service”) is a platform of the BlackNorth Initiative (the “BlackNorth Initiative,” “we,” “us,” “our”), a non-profit organization located at 130 King St W Suite 2950, Toronto, ON, M5X 1K6. As applicable and unless otherwise specified, reference to the BlackNorth Initiative includes its Members, directors, officers, mentors, employees, contractors, subcontractors, freelancers, agents, representatives, successors, assigns, and affiliated, related, and subsidiary organizations.

• Accountability

  The BlackNorth Initiative respects and endorses Service users’ rights to privacy and to understand how and why we collect, use, safeguard, and disclose personal information. It is to be noted that if a user creates an account (membership) and agrees to receive information and updates, public disclosure of personal information to third parties is inevitable, and public disclosure may occur.

  The BlackNorth Initiative respects the privacy decisions individuals make. However, the Service cannot be provided if some personal information is not disclosed in the course of accessing and using the website

  This Privacy Policy explains how we collect, use, disclose, safeguard, and dispose of Members' personal information, as well as other rights Members have concerning that information.

• Notice

  Some of the resources referenced in this Privacy Policy may not yet be offered. All are likely to be expanded over time.

• Personal Information

  Two types of personal information are subject to privacy rights.

  The first is information that identifies a specific person (either alone or combined with other information).

  If it is rare enough, a person’s name alone can constitute personal information. If it is not sufficiently uncommon (and most people’s names are not), an individual’s name combined with a second piece of information is an example of personal information. Home address, email address, telephone number, social media identifier, age, nickname, a detailed description of physical features, the neighbourhood in which the person lives, where they went to school, and their medical history are examples of information that would be personal information when combined with a name or other identifier.

  The second type of protected personal information is anything of a personal nature about an identifiable individual.

  Examples of this kind of personal information include:

  • The person’s race, national or ethnic origin, colour, religion, age, sex, sexual orientation, or marital or family status.
  • The person’s education or medical, psychiatric, psychological, criminal, or employment history.
  • The person’s financial status or information relating to financial transactions in which the person has been involved.
  • The person’s social security number or another unique number or identifier assigned to them.
  • The person’s fingerprints or blood type.
  • The individual’s personal opinions or views about social or political issues.
  • The views or opinions of others about the person.
  • Generally, any information that could prove embarrassing or harmful to an individual’s reputation or that a reasonable person would not want to be in the public domain.

• The Personal Information We Collect

  The personal information we collect from Members may include and its use is limited to:

  • Identification information necessary for Members to create accounts and use the Service. That information includes or may include name, email address, telephone number, province of residence, company name and industry, and racial identification (self-identification as Black). This information is for the BlackNorth Initiative’s internal use and not for public disclosure.
  • Information that helps us improve BlackNorth Initiative programs and services, including the BEGIN Service, and our program/service access and delivery processes.
  • Information to conduct Member relationship audit and management procedures, as well as marketing and advertising initiatives, including identifying program/service improvements and additional programs or services that may be of interest to Members.
  • Information that will help us better manage and improve Members’ overall relationship with us so that they continue participating in our programs/using our services, including improving Member experiences on this website.
  • For additional information about points b., c., and d. on this list, see Other Information We Collect.

• Why We Collect Personal Information and Members’ Consent

  We collect personal information so that Members can access and use the Service, including confirming their eligibility to do so, as well as to permit us to protect/maintain the security of other Members, the website, our programs/services, and, as applicable, third parties contacted by Members through or by way of the website, and for other reasons described in this Privacy Policy.

  Examples of the type of non-personal information we collect for these purposes and how we collect it can be found in Other Information We Collect.

  In all instances, we only collect personal information for the purposes outlined in this Privacy Policy. We do not collect personal information for any other purpose, i.e., we do not collect personal information that is not needed for Members to access (and, if applicable, purchase) and use our programs/services or for us to communicate with Members, including if the Member has consented to receive information, (i) providing program/service updates and support, (ii) conducting our non-profit activities (e.g., keeping proper records), and (iii) improving or adding to our programs/services or the Service, all of which are legitimate activities of an organization such as the BlackNorth Initiative.

  The BlackNorth Initiative does not provide programs for or deliver services to, or knowingly collect personal information from, minors (children). If an individual has not reached the age of majority (18 in Ontario), they must not (i) enter any personal information in any form on the website, (ii) provide personal information any other way, (iii) attempt to participate or our programs by, for example, creating an account/membership, or (iv) continue to browse the website.

  Members expressly consent to our collection and use of personal information by reviewing this Policy (mandatory) and clicking the “I have read the Privacy Policy and agree to the collection of personal information” checkbox when creating an account. By continuing to access our programs/services through the website, Members indicate their continuing consent to our use of the personal information collected.

  An individual wishing to create an account and access the Service but who is unwilling to provide the personal information we require may contact our Privacy Compliance Officer (PCO) at support@blacknorthbegin.ca to discuss if and how this can be accomplished. When contacting our PCO, please indicate “Exemption Inquiry” in the subject line.

  An individual who creates an account/becomes a Member and provides personal information but subsequently changes their mind may contact our PCO at suppport@blacknorthbegin.ca. When contacting our PCO for this purpose, please indicate “Removal of Personal Information” in the subject line. We will cancel the Member’s account and make commercially reasonable efforts to delete and permanently destroy the personal information collected. Non-personal information will not be deleted.

  By browsing the website, individuals who have not created accounts (“Visitors”) consent to our collection and use of non-personal information as outlined in this Policy.

  Visitors who do not want us to collect or use non-personal information are advised not to browse the website.

  If an individual contacts us by a means other than the website, they consent to our collection and use of any personal information they provide. That use may include email marketing, from which individuals may unsubscribe.

  Should we wish to use personal information for any purpose other than as outlined in this Policy, we will first obtain consent to that use.

• Internal/Third-Party Contractor Access to Personal Information

  Access to personal information provided for our internal use is limited to BlackNorth Initiative employees who require it to (i) develop and provide our programs/services, and (ii) provide customer support. The personal information made available to employees is limited to the information they need to do their jobs/provide their services.

  We may share personal information with organizations affiliated with the BlackNorth Initiative. If we do, we will require those organizations to adhere to this Policy or a materially identical privacy policy.

  If a third-party contractor has or could have access to personal information, we require that contractor to treat it as confidentially as we do. A website developer and an IT contractor providing system maintenance are examples of third parties that may have access to personal information in the course of providing services to us. Other third-party services that will or may involve access to personal information include payment processing, customer service, data analysis, hosting services, marketing, and product development. Specific third-party contractors to which we provide personal information are identified in Other Information We Collect.

• External Disclosure of Personal Information

  Other than as detailed in this Policy, the BlackNorth Initiative does not disclose personal information to third parties except in situations in which a reasonable person would expect it to be disclosed. An example is if we hired a third party to provide customer support (e.g., Help Desk) services.

  Partners.The BlackNorth Initiative discloses personal information to Partners on the Service. Partners are organizations and companies with which Members can connect on the Service. Partners provide a variety of services Members may wish to access, including:

  • Learning – Education/training resources to help Members acquire the knowledge and information necessary to launch and grow their businesses.
  • Professional Services – Support small businesspeople require to launch and grow their businesses, including Legal Services, Marketing Services, Leadership & Management (Executive Coaching) Services, Bookkeeping & Accounting Services, and Funding Services (Loans, Grants, Venture Capital).
  • Mentorship – 1-on-1 mentorship matching and incubator/accelerator mentorship programs, as well as the Digital Boost mentorship platform.

  Personal information is disclosed to facilitate Partners providing pro bono and discounted offerings in return for the right to market to Members. Members are consenting to Partners contacting them for marketing purposes by creating an account.

  Other External Disclosure. The BlackNorth Initiative discloses personal information if required to do so by Court order or operation of law (e.g., receipt of a subpoena or summons). Unless legally prevented from doing so, we will first attempt to advise the Member that we have received an order or direction to disclose personal information so that the Member can challenge the order if they see fit.

  We disclose personal information to the proper authorities if necessary to report criminal or probable criminal activity, including fraud against us or one of our Members or Content providers, or to protect the security of our Members, Content providers, and their property, including their intellectual property. Members consent to the reasonable exercise of our discretion in such matters.

  We do not sell personal information.

• Retention of Personal Information

  We retain personal information as long as Members maintain their accounts. We delete all information (personal and non-personal) when a Member deletes their account.

  We make commercially reasonable efforts to delete information within 30 days of account deletion cancellation or as soon thereafter as possible.

  When we dispose of personal information, we do so in a way that prevents a privacy breach, i.e., by securely shredding paper files and completely and permanently deleting electronic records. Any information retained purely for statistical purposes will be rendered anonymous and no longer personal information.

  If instructed to do so by a Member, we will dispose of personal information. Please contact our PCO at support@blacknorthbegin.ca, if you wish to have your personal information deleted from our records. When contacting our PCO for this purpose, please indicate “Removal of Personal Information” in the subject line.

• Accuracy of Personal Information

  We make commercially reasonable efforts to ensure that personal information is accurate, complete, and up to date.

  For that purpose, we may require Members to confirm/update information from time to time. We are not responsible for the inaccuracy or incompleteness of information if a Member fails to update us in a timely manner.

• Safeguards

  We use industry-standard administrative, electronic (HTTPS over TLS encryption), and physical security measures to prevent unauthorized access to Members’ personal information.

• Data Breaches

  While we take commercially reasonable steps to secure personal information, no security measures are perfect or impenetrable, and no method of data storage or transmission can be guaranteed against any interception or other misuse. In particular, any information stored online is vulnerable to interception and misuse by unauthorized parties.

  In the event of a data breach that poses a real risk of significant harm to Members, we will take the following steps

  • Notify Members of the breach if their personal information was or may have been accessed or affected.
  • If known, advise Members of the specific personal information that was or may have been accessed or affected.
  • Advise Members of steps they can take to reduce the risk of harm from the breach, e.g., changing passwords or monitoring accounts.
  • Advise Members when the breach has been addressed and the risk to data has abated.
  • Advise applicable government authorities of the breach if required to do so by law.

• Members' Access to Their Personal Information

  Members are entitled to know their personal information in our records.

  Members requiring a copy of their personal information may contact our PCO at support@blacknorthbegin.ca. When contacting our PCO for this purpose, please indicate “Access to Personal Information” in the subject line.

  If personal information in our records is inaccurate or incomplete, please advise our PCO and we will correct it.

• Compliance

  The BlackNorth Initiative’s program/services, including the Service, are intended exclusively for Members in Canada.

  Therefore, this Privacy Policy and our protection of personal information practices comply with the laws in Canada. There is no reason for someone outside of Canada to create an account to access our programs/services, which will be of no value to them. Residents of, in particular, California, the countries in the European Economic Area, and the U.K. are advised that our personal information practices may not fully comply with the legal requirements of those jurisdictions.

  If you reside outside of Canada and believe you have a legitimate reason to create an account and access our programs/services, please contact our PCO at support@blacknorthbegin.ca before doing so. When contacting our PCO for this purpose, please indicate “International Privacy Inquiry” in the subject line.

• The BlackNorth Initiative’s Privacy Compliance Officer

  We have designated an appropriate representative as our Privacy Compliance Officer. The PCO is empowered to ensure compliance with our confidentiality of personal information obligations.

  Contact our PCO at support@blacknorthbegin.ca about any privacy or security of personal information questions or concerns you may have. When contacting our PCO for this purpose, please indicate “General Privacy Inquiry” in the subject line.

• Other Information We Collect

  Each time someone visits the website or otherwise connects with us electronically, we collect certain information. This information might be about the Visitor’s preferences or device. We use this information to ensure the website works as Visitors (which includes, as applicable, Members) expect it to, and to provide Visitors with a more personalized experience on the website. We may also use it to, for example, understand where Visitors to the website are generally located so that, if necessary, we can adjust SEO parameters to more accurately limit Visitors to those from the country (Canada) in which the BlackNorth Initiative offers programs/services.

  This type of information does not typically identify Visitors personally, although in some instances it might be possible to use it for that purpose (or at least to narrow down a Visitor’s identity to one of a small number of people). However, such information is not collected, and will not be used, for that purpose by The BlackNorth Initiative.

  Other examples of this largely anonymous type of information that we collect or may collect include the date and time of a visit or connection, the Visitor’s browser type, the Visitor’s Internet Service Provider and IP address, the site the Visitor visited before or after the website (“navigation history,” “referring site”), and the pages on the website that were viewed. In isolation, a single piece of such information does not necessarily identify a Visitor but, in some cases, it could be used in combination with other information to identify an individual Visitor, particularly if the Visitor provided us with some personal information at the time of their visit or connection.

  In addition to using this information to optimize the website, we use it for our internal security audit log, usage and trend analysis, system administration, and to gather aggregate demographic information about our Visitor and User bases for market identification and related purposes, including how Users interact with our programs/services on the website. We share this information, including personal information, with third parties that provide services to us, including analysis, storage, and data aggregation/organization.

  Because such information could, in some cases, be used to identify an individual, we treat it as personal information. This means we only use it for the legitimate purposes of providing our programs/services and advancing our mandate of empowering the next generation of changemakers from the Black Community by providing access to Content of value to entrepreneurs. We do not use it for any other purpose.

  By using the website or otherwise connecting with us electronically, Visitors acknowledge that they understand that we collect information of the nature described, i.e., anonymous/anonymized information. If a Visitor objects to our gathering information of this type, the User is advised not to use the website or connect with us electronically.

  Cookies

  Cookies are small text files that are placed on computers by websites. They are widely used to allow websites to work properly and be more user-friendly, remember preferences, improve experience, and provide website owners/operators with information they use for legitimate business/non-profit purposes. A description of what cookies are and how they work can be found here.

  We may use cookies for all of the reasons listed.

  Cookies placed by the website may be from third-party companies that provide us with analytics and other services. The information collected helps us understand how users interact with the website and, in some cases, how users access and use our programs/services so that we can identify new programs or services to offer and improvements/upgrades to existing programs/services that will add value for, in particular, Members.

  Google

  We use the Google Analytics suite of tools. Google (Alphabet Inc.) uses cookies to help us better understand how the website and our Service are being used including the number of Visitors, session statistics (the pages visited, how long Visitors stay on the website), approximate geolocation, and browser and device information.

  In particular, we use Google Tag Manager, a Google Analytics tool, to manage tags. Marketing tags are segments of code on a website that track user actions and collect data. Specific actions on a website trigger tags to collect data about the activity and send it to an analytics tool. Different tags serve different functions: Pageview Tags monitor visits to pages on a website; Conversion Tags track, for example, each time a sale (connection) is made or a form is filled out.

  We use the Google Search Console to obtain search-engine-related data to help us optimize traffic to the website. Examples of search-engine-related data include user queries and the number of times the website’s URLs appear in search results (impressions), along with post-click data about website engagement like bounce rates and e-commerce conversion rates.

  Google policies require that no data be passed to Google that Google could recognize or use as personal information. More information about Google’s policies is here.

  Ad Services

  We may use Google Ads to highlight the Service when Google’s search engine is used. We do not disclose personal information when we use Google Ads.

  We may use Meta Ads to advertise on, for example, Facebook and Instagram. We may disclose aggregate, anonymous data about users and visits to the website to Meta but we do not disclose personal information.

  We may also use similar services to highlight the Service/our programs/services on similar sites (e.g., LinkedIn).

  Other Service Providers

  In addition to those mentioned previously, third-party companies provide us with data processing and storage services. To maximize data security, we prefer not to disclose where our data, including Members’ personal information, is stored. If you wish to learn more about our data processing and storage service providers, contact our PCO at support@blacknorthbegin.ca. When contacting our PCO for this purpose, please indicate “Data Storage Inquiry” in the subject line.

  We provide our data processing and storage service providers with Members’ personal information. We acknowledge that the BlackNorth Initiative is ultimately responsible for the security of personal information provided to us. We are satisfied that these providers properly protect and lawfully use the personal information in their possession.

  Other User-Tracking Technologies

  We may use web beacons (sometimes called trackers). Web beacons allow the owner of a website to count the number of users who click on an advertisement for its product or service on a third-party site (in order to assess the value of advertising on that third-party site). Web beacons collect only specific information, such as a cookie number, time and date of visit, and a description of the page on which the web beacon is installed. Personal information is not collected.

  It is not possible to opt out of web beacons used on web pages. However, because web beacons are used together with cookies, their use can be limited by deleting cookies or changing browsers’ cookie settings.

  Managing Cookies Settings

  Cookie settings can be managed to clear or block specific cookies or all cookies. However, a user who blocks all of the cookies that we use may find their experience affected or that the website loses most or all of its functionality. Cookie settings are accessed via browser settings. Please keep in mind that by clearing all cookies, all website preferences will be lost.

• Amendments to this Privacy Policy

  We amend this Privacy Policy from time to time. If the Date of Last Amendment is later than the last time you read it, please review this Policy again. Continued use of the website or Services constitutes continued consent to our collection, use, and disclosure of personal information in accordance with this Policy.