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True North Governance, LLC
Privacy Policy

Effective Date: June 1, 2026  |  Last Updated: June 1, 2026

1. Who We Are

True North Governance, LLC (“TNG,” “we,” “us,” or “our”) is a single-principal governance consulting practice based in Redmond, Oregon. We help small businesses and Alaska Native Corporations build the internal policies, standard operating procedures, desk guides, and operational manuals their teams need to operate consistently and meet federal requirements.

 

This Privacy Policy explains how we collect, use, and protect personal information gathered through www.tngovern.com (the “Site”) and our client communications. It also describes your rights under the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA) and the EU General Data Protection Regulation (GDPR).

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Controller / Business: True North Governance, LLC, Redmond, Oregon 97756

 

Contact: Greg Hellesto — greg@tngovern.com

2. Information We Collect

We collect limited personal information through two channels.

2.1 Information You Provide Directly

When you submit the contact form on our Site, you provide:

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  • First name and last name

  • Company name

  • Email address

  • Phone number

  • Your message or inquiry

 

When you communicate with us by email or phone, we retain the content of those communications and any information you share.

2.2 Information Collected Automatically

Our Site is hosted on the Wix platform. Wix and its integrated tools automatically collect certain technical data when you visit:

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  • IP address and approximate geographic location

  • Browser type, version, and operating system

  • Pages visited, time on page, and referring URL

  • Device type and screen resolution

  • Cookie identifiers and session data

 

This data is collected through cookies, web beacons, and similar tracking technologies. See Section 5 (Cookies) for details.

2.3 Information We Do Not Collect

We do not process payment information through the Site. We do not knowingly collect personal information from individuals under the age of 16. We do not collect sensitive personal information as defined under CPRA, including Social Security numbers, government IDs, financial account credentials, biometric data, health information, or precise geolocation data.

3. How We Use Your Information

We use personal information only for the purposes for which it was collected:

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  • Responding to inquiries: To review and respond to your contact form submissions or direct messages.

  • Delivering services: To perform consulting, document development, and advisory work under client engagements.

  • Site operations: To maintain Site security, diagnose technical issues, and understand how visitors use the Site.

  • Legal compliance: To meet obligations under applicable federal and state law and to defend or establish legal claims.

 

We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects.

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data on the following lawful bases under Article 6 of the GDPR:

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  • Legitimate interests (Art. 6(1)(f)): Responding to business inquiries you submit through our contact form. Our legitimate interest is conducting our consulting practice. This processing does not override your fundamental rights.

  • Performance of a contract (Art. 6(1)(b)): Processing necessary to deliver services you have engaged us to perform.

  • Consent (Art. 6(1)(a)): For non-essential cookies and tracking technologies. You may withdraw consent at any time without detriment.

  • Legal obligation (Art. 6(1)(c)): Processing required to comply with applicable law.

5. Cookies and Tracking Technologies

The Site uses cookies and similar technologies. As a Wix-hosted site, some cookies are placed by Wix and its service partners, not directly by TNG.

5.1 Types of Cookies

  • Strictly necessary cookies: Required for the Site to function (e.g., session management, security). These cannot be disabled.

  • Analytics and performance cookies: Used to understand how visitors interact with the Site, typically placed by Wix Analytics.

  • Functional cookies: Remember your preferences and improve your experience.

5.2 Managing Cookies

You may configure your browser to refuse cookies or alert you when cookies are being sent. Disabling certain cookies may affect Site functionality. EEA and UK residents may withdraw consent for non-essential cookies at any time. For information on how Wix manages cookies, visit www.wix.com/about/privacy.

6. Sharing and Disclosure of Personal Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

We may share personal information in the following limited circumstances:

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  • Service providers: Wix (website hosting) and Microsoft (email) process personal data on our behalf and are contractually restricted from using your data for any other purpose.

  • Legal requirements: If required by law, court order, or government authority, or as necessary to protect the rights, property, or safety of TNG or others.

  • Business transfers: In the event of a merger, acquisition, or sale of substantially all assets, personal information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

  • With your consent: For any other purpose with your explicit prior consent.

7. Data Retention

We retain personal information only as long as necessary for the purposes stated in this Policy or as required by law.

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  • Contact form inquiries: Retained for up to 24 months from receipt, or for the duration of a client relationship, whichever is longer.

  • Client engagement records: Retained for a minimum of 7 years following completion of an engagement, consistent with federal contracting documentation standards and applicable record-retention requirements.

  • Technical and analytics data: Retained as configured by the Wix platform, typically 26 months.

 

When retention periods expire, we delete or securely anonymize personal information.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. The Site is hosted by Wix, which maintains its own security infrastructure.

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No method of transmission over the internet is 100% secure. We cannot guarantee absolute security, but we will notify affected individuals of a breach that creates material risk of harm as required by applicable law.

9. International Data Transfers

TNG is located in the United States. If you access our Site from the EEA, UK, or Switzerland, your personal data will be transferred to and processed in the United States. We rely on Wix’s Standard Contractual Clauses (SCCs) established under EU Commission Decision 2021/914 as the safeguard for these transfers. For details, see www.wix.com/about/privacy.

10. Your Privacy Rights

10.1 California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights:

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  • Right to Know: Request disclosure of what personal information we have collected about you, the sources, our purposes for collection, and the third parties with whom we share it.

  • Right to Delete: Request deletion of personal information we have collected from you, subject to certain exceptions (e.g., completing a transaction, legal obligations).

  • Right to Correct: Request correction of inaccurate personal information we hold about you.

  • Right to Opt Out of Sale or Sharing: We do not sell personal information or share it for cross-context behavioral advertising. No opt-out is required, but you may confirm by contacting us.

  • Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information beyond the purposes permitted by CPRA.

  • Right to Non-Discrimination: We will not deny services, charge different prices, or provide a different quality of service based on your exercise of these rights.

 

To submit a California rights request, email greg@tngovern.com with the subject line “CCPA/CPRA Privacy Request.” We will respond within 45 days. We may extend this period by an additional 45 days with prior notice. You may designate an authorized agent to submit requests on your behalf; we will require written authorization and may verify the agent’s identity.

In the preceding 12 months, we have collected the following categories of personal information: identifiers (name, email address, phone number, IP address), professional or employment-related information (company name, service inquiries), and internet or network activity (Site usage data). We have not sold or shared any category for cross-context behavioral advertising.

10.2 EEA, UK, and Switzerland Residents (GDPR)

If you are located in the EEA, UK, or Switzerland, you have the following rights under the GDPR or applicable equivalent law:

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  • Right of Access (Art. 15): Obtain a copy of the personal data we hold about you.

  • Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.

  • Right to Erasure (Art. 17): Request deletion of your personal data where it is no longer necessary, where you have withdrawn consent, or where processing is unlawful.

  • Right to Restriction (Art. 18): Request that we limit processing of your personal data in certain circumstances.

  • Right to Data Portability (Art. 20): Receive personal data you have provided to us in a structured, commonly used, machine-readable format, where processing is based on consent or contract.

  • Right to Object (Art. 21): Object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

  • Right to Withdraw Consent: Where processing is based on consent, you may withdraw at any time without affecting the lawfulness of prior processing.

  • Right to Lodge a Complaint: You may lodge a complaint with your EU supervisory authority, the UK Information Commissioner’s Office (ICO), or the Swiss Federal Data Protection and Information Commissioner (FDPIC).

 

To exercise GDPR rights, email greg@tngovern.com with the subject line “GDPR Data Subject Request.” We will respond within 30 days. Complex or numerous requests may be extended by an additional 60 days with notice. We do not charge a fee unless requests are manifestly unfounded or excessive.

11. Children’s Privacy

The Site is directed to businesses and professionals. We do not knowingly collect personal information from individuals under the age of 16. If we become aware that we have done so without appropriate consent, we will delete that information promptly. Contact greg@tngovern.com if you believe we have collected information from a minor.

12. Third-Party Services

The Site is hosted on the Wix platform, which operates its own data practices governed by Wix’s Privacy Policy at www.wix.com/about/privacy. We are not responsible for the privacy practices of third-party websites linked to or from our Site and encourage you to review their policies.

13. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will update the “Last Updated” date at the top of this Policy and, where required by law, notify you directly. Your continued use of the Site after any update constitutes acceptance of the revised Policy.

14. Contact Us

For questions about this Privacy Policy, to exercise your rights, or to raise a concern about how we handle your personal information, contact:

Greg Hellesto, Principal

True North Governance, LLC

Redmond, Oregon 97756

Email:   greg@tngovern.com

Website:   www.tngovern.com

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