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Privacy Policy

Old North Foundation of Boston, Inc.


Website Privacy Policy

This Privacy Policy governs the manner in which the Old North Foundation of Boston, Inc. (“Old North,” “we,” “our,” “us” and similar terms) collects, uses, maintains and discloses information collected from users (a “user,” as well as “you,” “your” and similar terms) of our website (the “Website”).


By using the Website, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Website.


What Information Do We Collect and How Do We Collect It?

We and our third party service providers may collect all or any of the following information:

  • Personal Information. “Personal Information” is information that you provide to us that can be used to identify you, such as your name, address, phone number, e-mail address, IP address and credit card information. We collect Personal Information from you that you voluntarily provide to us when you register for or use our Website, fill out a survey or other form, purchase tickets or our products, subscribe to a newsletter, mailing list or other communication tool, contact us via email, and in connection with other activities, services, features or resources we make available through the Website from time to time.
  • Aggregate Information. “Aggregate Information” is information that cannot be used to identify any particular individual, such as the type of browser and computer or mobile device our visitors are using, technical information about their means of connecting to our Website (e.g., the operating system and the Internet or mobile service providers utilized), information about other websites they have recently visited, their site activity, and the time and date of their visit, and other similar information. Aggregate Information may be collected when they visit or interact with our Website, independent of any information they voluntarily enter.
  • Cookies. A cookie is a data file placed on a device (such as your computer or smartphone) when it is used to visit our Website. Cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please aware that if you disable or remove cookies on your device, some parts of our Website might not function properly, and that when you revisit our Website your ability to limit cookies is subject to your browser settings and limitations.

What Do We Do With the Information We Collect?


Personal Information. We use Personal Information for the purpose for which it has been provided to us, as indicated on the form that the user fills out and/or questions that the user answers. These purposes may include providing you with information or services or processing transactions that you have requested or agreed to receive, including to send you electronic newsletters, or providing you with special offers or promotional materials on behalf of us or third parties. We will not sell or use your Personal Information for any other reason, except to the extent that you consent for us to do so, and in any event only as provided pursuant to this Privacy Policy. If a user does not wish to provide certain Personal Information requested on a given screen, or if he or she has concerns about maintaining the confidentiality of any information, we suggest that the user not provide the information. We limit access to Personal Information only to those individuals whose responsibility it is to address the user’s specific request.


Aggregate Information. We use Aggregate Information for a variety of purposes, such as to understand how our users as a group use the Website, to improve the Website, to personalize user experience, and to process transactions. We also use Aggregate Information to track numbers of visitors to our site and numbers of visitors to various sections of our site for the purpose of determining trends and user needs. Aggregate information is analyzed and used as input to help us improve our site.


When Do We Provide Information to Third Parties?


Service Providers. We may use third party service providers to perform certain services on our behalf on the Website, such as hosting the Website, processing payments, providing online tickets, tracking the Website’s activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these service providers with access to user information, including Personal Information, solely to the extent necessary to carry out the services they are performing. These third party service providers are not authorized to retain, share, store or use the Personal Information for any purposes other than to provide the services they have been hired to provide.


Third Party Ad Servers. We may also allow other companies, called third party ad servers or ad networks (“Ad Servers”), to serve advertisements on the Website. These Ad Servers use technology to send, directly to your browser, the advertisements and links that appear on the Website. They automatically receive your IP Address when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content. Further, these advertisers may also serve ads to you on other websites (including ads for our products and services) based on information collected from you while using the services available through the Website. For example, we use Google AdWords to target Old North ads to you based on your prior use of the Website when you visit other sites in Google’s content network.


You should consult the respective privacy policies of these Ad Servers. This Privacy Policy does not apply to, and we cannot control the activities of, such advertisers or other websites. You can opt out of the use by Ad Servers of cookies by contacting us at


Analytics. We use Google Analytics to help us understand how users use our Website, so that we may improve our services. Information about how Google Analytics uses data, and how you may control what information of yours is shared with Google, can be found here.


Without limiting the above, we may access, use, preserve, transfer and disclose your Personal Information to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the policies applicable to the Website, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Website or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues.


We reserve the right to disclose and transfer all user information: (a) to a subsequent owner, co-owner or operator of the Website or applicable database; or (b) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.


Legal Bases for Processing Information


We rely on the following legal grounds to process your Personal Information:

  • Performance of a Contract. We need to collect and use your Personal Information to perform our agreement with you to deliver the services available on the Website as described in this Privacy Policy.
  • Consent. We may use or disclose some of your Personal Information such as precise location information or collect cookies as described in this Privacy Policy subject to your consent.
  • Legitimate Interests. We may use your Personal Information for our legitimate interests to improve our products and services and the content on our Website. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Privacy Policy and use Personal Information for our marketing purposes.

Do You Retain and Delete My Data?


We will only retain your Personal Information (i) that is specific to a financial transaction until completion of such transaction or (ii) that you have provided in order to receive information about or communications from Old North (including through our newsletter) until you notify us that you would no longer like to receive such information or commutations. We may also retain Personal Information for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. In some circumstances, we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information.


It is our policy to retain Personal Information until (i) you ask us to delete your Personal Information or (ii) such Personal Information is no longer necessary to deliver services. Regarding types of information other than Personal Information we collect as described in this Privacy Policy (e.g., cookies), it is our policy to retain such information for up to 14 months or until such information is no longer necessary to deliver services.


Geographic Location and Security


For users within the United States, we process data in data centers located in the United States. We have adopted reasonable physical, technical, and organizational safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use, or processing of user data in our possession. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. We comply with state and federal laws governing the protection of personal information.


What If I Am Located in the European Union?


For users within the European Union (the “EU”), we transfer data from the EU to data centers located in the United States for processing, pursuant to your consent as indicated when requested. Such processing is performed in accordance with Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and free movement of such data, known as the General Data Protection Regulation (“GDPR”). This includes the imposition of required safeguards with respect to accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of data.


If you are a resident of the EU, you have the right to, as applicable under the GDPR:

  • Request an accounting of all Personal Information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
  • Request that we correct or update any Personal Information that pertains to you.
  • Request that we delete any Personal Information that pertains to you.
  • Fully or partially withdraw your consent to the collection, processing, and/or transfer of your Personal Information.
  • To request an accounting of your Personal Information, a correction or update to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your Personal Information, please contact Pamela Bennett at (617) 523-4848 or Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

How Do I Change My Information And Communications Preferences?


You are responsible for maintaining the accuracy of the information you submit to us. You may provide corrections and updates by contacting us at: If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
Please note that we reserve the right to send you certain communications relating to use of our Website, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about: your Privacy Policy or practices described in it, you should contact us by e-mail:


What Should Parents Know About Children?


This is a general audience Website and we do not knowingly collect any Personal Information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any Personal Information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed Personal Information to us, please contact us at


Will This Policy Change?

We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Your continued use of the Website following the posting of revisions to this Privacy Policy will be deemed your acceptance of such revisions. We encourage users to frequently check the email account that they use in connection with the Website, as well as this Privacy Policy, to stay informed about any changes to this Privacy Policy. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically. The date at the bottom of this Privacy Policy will be updated for each revision. Notwithstanding the above, we will not use your Personal Information in a manner materially different than promised at the time it was collected without your consent.




This Privacy Policy will be governed by and construed in accordance with the laws of the Commonwealth of Massachusetts, USA, without regarding to conflicts of law principles. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.


Questions or Concerns


If you are located in the United States or any region other than the EU, you can direct any questions or concerns regarding the use or disclosure of your information, or any other matter related to this Privacy Policy, to: Old North Foundation of Boston, Inc., 193 Salem St., Boston, MA 02113, Attention: Pamela Bennett, Director of Retail and Operations; or by sending an email to


Our representative in the EU for GDPR purposes is Foley Hoag AARPI. You can contact our representative at the following address: 153 rue du Faubourg Saint-Honoré 75008 Paris, France.


Effective Date: September 12, 2018

Contact Information

193 Salem St
Boston, MA 02113

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