Eastern Band of Cherokee Indians Privacy Policy
Effective: 02/01/2024
We at the Eastern Band of Cherokee Indians (EBCI), respect your concerns about privacy. This Digital Privacy Policy (“policy”) describes the types of personal information we may obtain when you visit and use the Client Portal which exists to register for services (“services”) provided by EBCI programs, how we may use the information, with whom we may share it, and the choices available regarding our use of the information. The policy also describes the measures we take to safeguard your personal information and how you can contact us about privacy practices.
It applies generally to the following groups:
• Customers and users (including prospective customers and users);
• Employees;
• Third party business partners; and
• Other individuals who interact with us or whose personal information we maintain.
Changes to This Privacy Policy
We reserve the right to change this policy at any given time and we will notify you of any changes by posting the Privacy Policy on the Client Portal. We will let you know via email and/or a prominent notice on our portal, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
What Personal Data Do We Collect
At EBCI, we strive to limit the types and categories of personal data that is collected from and processed on behalf of our users to include only data which is necessary to achieve the purpose(s) for which it was collected. We do not use personal data for additional purpose(s) which are incompatible with their initial collection. In other words, we have measures and policies in place designed to ensure that we only collect and process data from our users that we believe is necessary to provide them with a world-class Service.
Data We Collect Directly from You
When you interact with the Client Portal, or use our services, you may provide us with the following categories of personal data:
• Customer Account Data. Your email is needed to validate, create, and use our services. However, you must also provide identifiers such as first and last name, enrollment number, address, and phone number to help maintain and support your account.
• A Note Regarding Your Mobile Phone Number. You may provide us with your mobile phone number if you set up two-factor authentication and/or opt-in to our SMS account recovery feature. By opting into SMS account recovery, you consent to receiving autodialed text messages, including SMS messages, that may be sent by or on behalf of EBCI at the mobile phone number you provide us. Message and data rates may apply.
• A Note Regarding Your Password. Users must create a “Password,” which is used when you access the Client Portal and subsites provided by the different EBCI programs.
• A Note Regarding Comments. It is EBCI’s policy that any comments that contain spam or are improper, inflammatory, off-topic, or offensive shall be removed. Repeat offenders may be subject to banning.
How We Collect Your Data
• Direct Interactions. You provide your personal information when you interact with us, such as when you register for Services, fill in forms, communicate with us, apply for jobs, and work for us.
• User Contributions. We collect your personal information when you or others upload, share, send, or input that information through our Services or networks, or when you or they communicate with us.
• Automatically. We automatically collect personal information about you when you interact with us, such as when use our Services, visit our offices or events, open emails or view advertisements from us, or communicate with us. We may collect some of this personal information by using cookies and other similar technologies.
• Third Party or Publicly Available Sources. We may receive your personal information from third parties, such as our third-party business partners (including data brokers and advertising partners), your organizations, governmental agencies who publish public records, and other publicly or generally available sources (including online websites).
Why We Collect Your Data
We are collecting your data for several reasons:
• To provide and manage our Services, including to process, evaluate, communicate, and fulfill requests, inquiries, and claims we receive in connection with our services.
• To create, manage, administer, and communicate with you about your account, including identifying and authenticating you so you may access your account or use certain features of our services.
• To manage customer accounts, manage our relationship with you, and send you administrative and product notifications about the services.
• To provide customer and technical support.
• To process, evaluate, and respond to requests, inquiries, and applications we receive in connection with our services.
• To administer our services and meet our obligations under the applicable Terms of Use and service options you request.
Information Sharing
We do not sell or otherwise share personal information about you except as described in this Digital Privacy Policy. We may share your personal information with third parties who are providing the product, service, or information that has been requested on behalf of EBCI.
Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the service on our behalf, perform service-related services, or assist us in analyzing how our service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We may disclose personal information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with legal requests, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
Safeguarding and Securing the Data
The Eastern Band of Cherokee Indians is committed to securing your data and keeping it confidential. EBCI has done all in its power to prevent data theft, unauthorized access, and disclosure by implementing the latest technologies and software, which help us safeguard all the information we collect online. The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
How Long Do We Process Your Personal Data
We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Our Cookie Policy
When you interact with our Digital Services or open our emails, we may obtain certain information by automated means, such as browser cookies, web beacons, device identifiers, server logs, and other technologies. A “browser cookie” is a text file that we save on your device when you use our Digital Services. Cookies allow us to uniquely identify users and to store information or settings. You can manage cookies through your web browser. Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie and how to disable existing cookies. You can find out how to do this for your browser by clicking “help” on your browser's menu or by visiting www.allaboutcookies.org. In addition, your mobile device settings may allow you to prohibit mobile app platforms (such as Apple and Google) from sharing certain information obtained by automated means with mobile app developers and operators such as us. Please note, however, that without cookies and similar technologies we use, you may not be able to take full advantage of all features of our Digital Services. Please note that cookies don't allow us to gain control of your computer in any way. They are strictly used to monitor which pages you find useful and which you do not so that we can provide a better experience for you. If you want to disable cookies, you can do it by accessing the settings of your internet browser. You can visit https://www.internetcookies.com, which contains comprehensive information on how to do this on a wide variety of browsers and devices.
Restricting the Collection of your Personal Data
At some point, you might wish to restrict the use and collection of your personal data. You can achieve this by doing the following:
• If you have already agreed to share your information with us, feel free to contact us via email and we will be more than happy to change this for you.
Children's Privacy
Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.