AIMHITN | EASy 7.9

AIMHITN

Registration

MyEASy.org Privacy Policy (GDPR Compliant)

Effective Date: 12/01/2025

IECMH International Institute (“we,” “us,” or “our”) is committed to protecting the privacy and security of your personal data. We act as the Data Controller for the personal data processed in connection with our website, myeasy.org, and the application EASy (collectively, the “Site”). This Privacy Policy explains how we collect, use, and safeguard your information and outlines your rights under the General Data Protection Regulation (GDPR), which applies to the personal data of individuals located in the European Economic Area (EEA) and the UK.

Please read this Privacy Policy carefully. By using EASy, you acknowledge and accept the practices described herein.

1. Changes to This Policy

We reserve the right to modify this Privacy Policy. We will alert you to any significant changes by updating the “Effective Date” and taking reasonable steps to notify you, such as via email or a prominent notification upon logging into EASy. Any changes will be effective immediately upon posting the updated Privacy Policy.

2. Data Controller and Contact Information

The Data Controller responsible for the processing of your personal data is:

IECMH International Institute
Contact: endorsementInstitute@gmail.com
Address: 13101 Allen Road, Southgate, Michigan 48195

3. Collection of Your Information and Lawful Basis

We collect information necessary for specific, explicit, and legitimate purposes. The categories of data we collect, and the corresponding lawful basis under GDPR, are:

Data Category	Examples of Data Collected	Lawful Basis for Processing
Personal Data	Name, address, email, telephone number.	Consent (for account creation and communications) or Contractual Necessity (for membership management).
Special Category Data	Demographic data such as race/ethnicity.	Explicit Consent (as required by GDPR, to be obtained via an affirmative, separate opt-in).
Derivative Data	IP address, browser type, operating system, usage patterns.	Legitimate Interest (to ensure network security and improve service delivery).
Financial Data	Transaction ID, date/type of payment. (No full payment card data is stored by us.)	Contractual Necessity (to process payments for services).
Mobile Device Data	Device model, manufacturer, location information (if enabled).	Consent (for optional location services) or Legitimate Interest (to optimize the mobile application).

Note on Refusal: You are under no obligation to provide us with personal information. However, your refusal to provide data based on Contractual Necessity or Consent may prevent you from using certain features.

4. Use of Your Information and Purpose

We process your personal data for the following purposes, based on the legal grounds identified above:

Processing Purpose	Lawful Basis
Service Delivery & Management
Create, manage, and email you regarding your account. Process payments and refunds. Resolve disputes and troubleshoot problems.	Contractual Necessity
Business Operations & Improvement
Monitor and analyze usage/trends to improve EASy efficiency. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity. Compile anonymous statistical data and analysis (if fully anonymized).	Legitimate Interest
Communication & Marketing
Contact you with information on Endorsement®, your membership, or other initiatives. Send you a newsletter or solicit support.	Consent or Legitimate Interest
Legal Compliance
Assist law enforcement, respond to subpoenas, or protect our rights/property/safety.	Legal Obligation

5. Disclosure and Recipients of Your Information

We may share your information with the following categories of recipients, strictly on a need-to-know basis and under protective contracts:

Payment Processors: Stripe or PayPal (only Financial Data, necessary for transaction completion).
Affiliates: IECMH International Institute and other infant and early-childhood mental health organizations. We require all affiliates to honor this Privacy Policy.
Law Enforcement & Legal Parties: When legally required or necessary to protect our rights (see Legal Obligation above).
Interactions with Other Users: If EASy includes user interaction features, other users may see your name and descriptions of your activity.

International Transfers: If your data is transferred outside the European Economic Area (EEA), we will ensure that an appropriate safeguard is in place, such as Standard Contractual Clauses approved by the European Commission, to ensure the level of data protection is not undermined.

6. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Account Data: Retained for the duration of your active membership/account and for a period of up to 60 days thereafter, unless a longer retention period is legally required.
Financial Records: Retained for the period required by tax and accounting law, 7 years.

7. Your Data Protection Rights (GDPR)

Under GDPR, you have the following rights concerning your personal data. You may exercise these rights by contacting us using the information in Section 2.

Right	Description
Right to be Informed	To be informed about how your data is processed (this Policy serves this purpose).
Right of Access	To request a copy of the personal data we hold about you.
Right to Rectification	To request that we correct any inaccurate or incomplete data we hold about you.
Right to Erasure (The "Right to be Forgotten")	To request the deletion of your personal data when there is no compelling reason for its continued processing.
Right to Restriction of Processing	To request that we limit the use of your data under certain circumstances (e.g., if you contest the data’s accuracy).
Right to Data Portability	To receive your data in a structured, commonly used, and machine-readable format and to transfer it to another controller.
Right to Object	To object to processing based on legitimate interest or for direct marketing purposes.
Right to Withdraw Consent	To withdraw your consent at any time where processing is based on consent. Withdrawal does not affect the lawfulness of processing before the withdrawal.

Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your member state if you believe your rights under GDPR have been violated.

8. Tracking Technologies (Cookies)

We use cookies and similar tracking technologies. GDPR requires that we obtain your opt-in consent before placing non-essential cookies on your device.

We use a cookie consent banner to provide you with control over which cookies are set.
By default, only essential cookies are active.
You can manage your preferences at any time.

Please refer to our separate Cookie Policy below for detailed information on the types of cookies we use, their purpose, and their retention periods.

9. Security of Your Information and Breach Notification

We employ administrative, technical, and physical security measures to protect your personal information. While we strive to protect your data, no method of transmission is 100% secure.

Data Breach Response: In the unlikely event of a personal data breach, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible. If the breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay.

10. Emails and Communications

You may opt-out of receiving non-essential correspondence, emails, or other communications from us at any time by:

For non-EASy messages, click the “unsubscribe” link at the bottom of any marketing email.

MyEASy.org Cookie Policy

Effective Date: 12/02/2025

This Cookie Policy explains how IECMH International Institute ("we," "us," or "our") uses cookies and similar technologies (such as web beacons and pixels) on the EASy application and website (the “Site”). This policy should be read alongside our Privacy Policy.

1. What are Cookies?

Cookies are small text files placed on your device (computer, tablet, or mobile) when you visit our Site. They are widely used to make websites work more efficiently and to provide reporting information.

2. Why We Use Cookies (Purpose and Lawful Basis)

We use cookies for the following purposes:

Category	Purpose	Lawful Basis (GDPR)
Strictly Necessary	To enable core functionality (e.g., login, security, payment processing). The Site cannot function properly without these.	Legitimate Interest (essential for service delivery).
Analytical/Performance	To collect data on how users interact with the Site (e.g., pages visited, error rates) to measure performance and improve the user experience.	Consent (User must actively opt-in).
Functionality	To remember your preferences (e.g., language or region) to provide a more personalized experience.	Consent (User must actively opt-in).
Marketing/Targeting	To track user activity across the Site and other sites to deliver personalized advertisements or communications.	Consent (User must actively opt-in).

3. Types of Cookies We Use

Cookies can be classified by duration:

Session Cookies: These are temporary and expire when you close your browser. They are typically used for necessary functions like maintaining a login session.
Persistent Cookies: These remain on your device for a set period specified in the cookie (unless deleted by the user). They are used to recognize you over time, such as remembering your preferences.

Cookies can also be classified by who sets them:

First-party Cookies: Cookies set by the Site itself (e.g., EASy).
Third-party Cookies: Cookies set by external services we use for analytics, advertising, or functionality (e.g., Google Analytics, Stripe).

4. How to Manage and Control Cookies

In compliance with GDPR, we provide you with granular control over non-essential cookies.

Cookie Banner: When you first visit EASy, you will see a banner allowing you to:
- Accept All Cookies.
- Reject All Non-Essential Cookies.
- Customize your preferences by category (Analytical, Functionality, Marketing).
Browser Settings: You can modify your web browser settings to delete or refuse cookies. However, please note that disabling strictly necessary cookies may negatively impact the functionality of EASy.
Opt-Out Tools: You can use industry-wide opt-out tools such as the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA).

MyEASy.org Data Subject Request (DSR) Process & Form Guidance

In accordance with your rights under the GDPR (outlined in Section 7 of the Privacy Policy), you may submit a request to exercise your data subject rights.

1. Submitting a Data Subject Request

To ensure your request is handled efficiently and securely, please submit your request to our designated privacy contact:

Email: endorsementInstitute@gmail.com
Subject Line: Data Subject Request – IECMH International Institute

2. Required Information

Your request must include the following information to allow us to verify your identity and locate your data:

Requirement	Purpose
Full Name	To match the request to the data subject.
Email Address(es)	The email address(es) associated with your EASy account or use of the Site.
Country of Residence	To determine the relevant legal framework (e.g., GDPR).
Specific Right Requested	Clearly state which right you are exercising (Access, Erasure, Rectification, Portability, Restriction, or Objection).
Detailed Description	A precise description of the data you are requesting, or the reason for your request (e.g., "I wish to receive all personal data processed in the last 12 months," or "Please correct my street address from X to Y").

3. Identity Verification

To protect your personal data, we must verify that you are the data subject making the request.

Standard Verification: We will generally verify your identity by sending a confirmation email to the address on file for the request.
High-Risk Verification (for Erasure/Portability): If the request involves sensitive data or deletion, we may require additional steps, such as confirming recent activity or providing a copy of a utility bill (with non-essential details).