Privacy Policy

Effective date: June 12, 2026. Last updated: September 26, 2026.

Internality ("Internality," "we," "us," or "our") is a Michigan nonprofit corporation recognized as tax-exempt under Section 501(c)(3) of the Internal Revenue Code. We operate the website internality.org (the "Site") and related programs and services. This Privacy Policy explains how we collect, use, share, and protect personal information, and the rights you have over that information.

This policy is written to meet the requirements of US privacy law and, where they apply, the EU General Data Protection Regulation (GDPR) and the UK GDPR / Data Protection Act 2018. If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the section "Your rights in the EEA, UK, and Switzerland" applies to you.

1. Who is responsible for your information

Internality is the data controller for personal information processed through the Site. You can contact us about this policy or your personal information at hello@internality.org, or for privacy requests at privacy@internality.org.

2. Information we collect

Information you provide directly. When you complete a contact or interest form, apply for membership, register for a program, or subscribe to communications, we collect the information you submit. This may include your name, email address, phone number, organization name, job title or role, organization type, your stated areas of interest, and the contents of any message you send us.

Gifts and purchases. When you make a gift or buy a Speaker Series subscription, we collect your name, email address, billing address, the amount and date of each payment, receipt numbers, the card brand and last four digits, your subscription status, and whether you agreed to receive email from us. For a subscription we also keep a record of the automatic-renewal terms you agreed to at checkout (the wording shown, its version, the price and the time you agreed). Your full card or bank details are collected by Stripe on its own checkout page; we never receive or store them.

Member portal and programs. If you are invited to a member account, we collect your account details, your participation in programs such as Pivot Labs, documents you or your company upload privately, and what you post in program discussions.

Speaker Series sessions. When you register for a session, we record your registration and attendance. Sessions are recorded (see section 5).

Information collected automatically. When you visit the Site, limited technical data is processed, including IP address, browser type and version, operating system, referring page, pages viewed, and the date and time of your visit. We use privacy-focused analytics for this. See our Cookie Policy for details on cookies and similar technologies and how consent works.

We do not intentionally collect special categories of personal data (such as health, religious, or political information), and we ask that you do not submit such data through the Site.

When you use our AI features, we also collect: the text of public guide-chat exchanges (anonymous, and only after automated redaction of personal details); member Inquiry conversations (stored for you, in your account); feedback ratings and comments you choose to give; and usage measurements (response times, token counts, model version, and quality scores) attached to a coded reference rather than to your identity.

3. How our AI features handle your information

Internality's guide chat and Inquiry run on our own AI model, on our own servers in Germany. Your questions to those tools are not sent to third-party AI providers.

The public guide chat is anonymous: we don't know who you are, and we don't try to find out. To improve answer quality, we keep a copy of chat exchanges for up to 90 days, after passing them through automated redaction that removes personal details: names, organizations, places, email addresses, and phone numbers. If that redaction is unavailable for any reason, we keep no copy of the text at all. Please still avoid including personal details in your questions. A random, temporary session marker (which disappears when you close the tab) lets us see that a conversation held together; it is never linked to an identity.

Inquiry (members) saves your conversations so you can return to them. That is the feature, and those conversations belong to your account: you can rename or delete them at any time, and deleting them deletes them. We do not store your questions or the AI's answers in our monitoring systems, ever. What we record are measurements (response time, error rates, and quality ratings) attached to a coded reference that stands in for your account.

To produce those quality ratings, an automated check on our own servers in Germany reads each exchange and rates it on things like whether the answer addressed the question asked. Nothing it reads is stored, sent anywhere, or seen by anyone. It runs on the same AI model we host ourselves, no outside company is involved, and the text is discarded the moment the rating is produced. Only the numbers are kept. If you would rather this did not run on your conversations at all, see Your choices below.

Feedback you choose to give (the thumbs-up/down and comments) is used to improve the AI. Comments pass through the same automated redaction; please don't include personal details.

Pivot Lab discussion summaries. In a Pivot Lab, the site can show participants a short automated summary of the lab's discussion. To produce it, recent posts from that lab's discussion (including the names shown on them) are sent to Anthropic, PBC (United States) through its commercial API, which does not use that content to train its models. The summary is shown only to that lab's participants and staff.

Speaker Series transcripts. Where a speaker has given written permission, a reviewed transcript of a session may be added to the source material our own AI tools search and cite, and may be used to improve Internality's own AI models, which run on our servers in Germany. Attendee questions and comments are removed from a transcript before it is used this way. Transcripts are not given or licensed to outside companies to train their models.

Where things live. Your account and conversations are stored with our database provider in the United States under the EU-approved safeguards for such transfers (standard contractual clauses and the EU-U.S. Data Privacy Framework). Our quality measurements and monitoring stay on our own infrastructure in Germany.

Your choices. Members can ask us to exclude their usage from quality monitoring entirely, and can request deletion of their data; deletion also scrambles the coded reference so historical measurements can no longer be connected to you. Write to privacy@internality.org.

When this changes. If we ever introduce a third-party service into evaluation of the anonymous guide chat (we plan to use one with a strict no-data-retention agreement), this notice will be updated first, and member conversations will remain excluded.

4. Gifts, subscriptions and payments

Payments on the Site are processed by Stripe, Inc., which collects your card or bank details directly on its secure checkout page and processes some information for its own purposes, such as fraud prevention, under its own privacy policy (stripe.com/privacy). Stripe sends us the payment details listed in section 2.

We use this information to process your gift or subscription, send receipts, manage recurring gifts and subscriptions (including renewal reminders, price-change notices, and cancellation confirmations), prevent fraud, and keep the financial records the law requires. Gifts and Speaker Series subscriptions are kept as separate records: a subscription is a purchase of a service, not a gift.

You can manage or cancel a recurring gift or subscription from your account page, with the cancel link in any Speaker Series receipt or reminder (no account needed), or by emailing giving@internality.org.

5. Speaker Series recordings, captions and transcripts

Speaker Series sessions are recorded. A recording can include the voices, video, names and chat messages of the speaker and of attendees who speak, turn on a camera, or post in chat. Each session page and every registration and reminder email says so, and explains how to take part without appearing: keep your camera off, choose your own display name, and send questions privately to the host. By registering and attending, you acknowledge the recording.

Sessions are held on Zoom, which creates the original recording. We store the recording with Cloudflare Stream, which hosts and streams it and generates captions automatically. Recordings are available only to signed-in subscribers and others Internality gives access, through time-limited links, and are not offered for download. We create a written transcript from the captions, may correct it, and store it in our own database; subscribers can read and search published transcripts. Speakers sign a release that sets out which of these uses they permit, and we publish only what each release covers.

If you appeared in a session and want your name or contribution removed from a recording, transcript, or AI source material, write to privacy@internality.org. We remove it from recordings and transcripts within 10 business days where practical, and from AI source material at its next update.

6. Why we use your information, and our lawful bases

Where the GDPR or UK GDPR applies, we rely on the following lawful bases (Article 6):

Respond to inquiries and requests: legitimate interests, or steps taken at your request prior to entering a relationship.

Administer membership, programs, and events: performance of a contract, and our legitimate interests in running the organization.

Process gifts and subscriptions, send receipts and subscription notices, and keep financial records: performance of a contract, and compliance with a legal obligation.

Record Speaker Series sessions and offer the recording archive: performance of a contract for subscribers, and our legitimate interests in offering the archive, balanced by the recording notice and the ways to take part without appearing.

Send marketing and program communications: your consent, which you may withdraw at any time.

Operate, secure, and improve the Site, including analytics: our legitimate interests, balanced against your rights.

Comply with legal, tax, and regulatory obligations: compliance with a legal obligation.

Protect the rights, property, and safety of Internality, our members, and the public: our legitimate interests, or a legal obligation.

Where we rely on legitimate interests, we have weighed those interests against your rights and freedoms. You can ask us about this assessment using the contact details above.

When you use our AI features, three further processing purposes apply. Storing your Inquiry conversations so you can save and resume them rests on contract necessity: it is the feature itself. Quality monitoring and improvement of our AI, including the automated in-process rating of Inquiry answers, rests on our legitimate interests, supported by a documented data protection impact assessment: the rating is transient, runs on our own hardware, produces numbers only, and your opt-out is honored before any processing. Feedback you choose to give is processed on the basis of our legitimate interests and is initiated by you.

The automated quality rating is used solely to improve the service; it produces no decision or effect concerning any individual member.

7. How we share your information

We do not sell, rent, or trade your personal information.

We share personal information with service providers (processors) who perform functions on our behalf under written agreements that require them to protect your data and use it only on our instructions. Our service providers are:

HubSpot, Inc. (US) for customer relationship management, forms, and email communications.

Stripe, Inc. (US) for payment processing for gifts and Speaker Series subscriptions.

Render Services, Inc. (US) for website hosting and infrastructure.

Cloudflare, Inc. (US) for content delivery, file storage, bot protection, and hosting, streaming and captioning of Speaker Series recordings.

Zoom Communications, Inc. (US) for hosting live Speaker Series sessions and creating the original recordings.

Neon (US) for database hosting for member accounts and conversations.

Clerk (US) for member authentication.

SendGrid (US) for transactional email, including receipts and subscription notices.

Anthropic, PBC (US) for the automated Pivot Lab discussion summary described in section 3.

Hetzner (Germany) for hosting our self-hosted AI model, community forum, and quality-monitoring infrastructure, operated by us.

Plausible Analytics (EU) for privacy-focused, cookieless website analytics.

We may also disclose information where required by law, subpoena, court order, or governmental request; to establish, exercise, or defend legal claims; or to protect the rights, property, or safety of Internality, our members, or others. If Internality is involved in a merger, reorganization, or transfer of assets, personal information may be transferred as part of that transaction, subject to this policy.

8. International data transfers

Internality is based in the United States, and several of our processors are located in the United States. When personal information is transferred from the EEA, the UK, or Switzerland to the United States or another country outside those regions, we rely on lawful transfer mechanisms: the EU-US Data Privacy Framework (and its UK extension and the Swiss-US Data Privacy Framework) where the processor is certified, and the European Commission's Standard Contractual Clauses (with the UK Addendum where relevant) as an additional safeguard, as provided in each processor's data processing terms.

AI queries to our guide chat and Inquiry are processed, and quality measurements are stored, on our own infrastructure in Germany. Member conversations are hosted in the United States by Neon under its data processing agreement, with standard contractual clauses as the transfer safeguard. Plausible processes analytics data within the EU.

9. How long we keep your information

We keep personal information only as long as necessary for the purposes described in this policy, then securely delete or anonymize it. In general:

Contact and inquiry submissions that do not lead to a relationship: up to 24 months.

Membership and program records: for the duration of the relationship plus a limited period required for legal, tax, and audit purposes.

Gift, subscription and payment records, including receipts and the record of the automatic-renewal terms you agreed to: 7 years after the last payment, for financial and legal records. These are kept even if you delete your account.

Session registrations and attendance: up to 3 years after the session.

Speaker Series recordings, captions and transcripts: for as long as the archive is offered, unless the speaker withdraws permission or an attendee removal request applies. We delete original Zoom recordings after they are transferred to Cloudflare Stream.

Transcripts in AI source material: until the speaker withdraws permission or the session is removed from the archive.

Marketing subscriptions: until you withdraw consent or unsubscribe, after which we keep a minimal suppression record so we do not contact you again.

Redacted guide-chat exchanges: up to 90 days. Quality measurements: retained as aggregates. Member Inquiry conversations: until you delete them. Website analytics: aggregated and retained only as needed to understand Site trends.

Deleting your Internality account does not cancel a recurring gift or subscription; cancel it as described in section 4.

10. Your rights in the EEA, UK, and Switzerland

If you are in the EEA, the UK, or Switzerland, you have the right to access the personal information we hold about you; to request rectification of inaccurate or incomplete information; to request erasure ("right to be forgotten"); to request restriction of processing in certain circumstances; to object to processing based on legitimate interests, and to object to direct marketing at any time; to request data portability where processing is based on consent or contract and carried out by automated means; and to withdraw consent at any time, without affecting processing carried out before withdrawal.

To exercise any of these rights, contact privacy@internality.org. We will respond within one month, as required by law, and will not charge a fee except where permitted. We may need to verify your identity before acting on a request.

You also have the right to lodge a complaint with a supervisory authority. In the UK, that is the Information Commissioner's Office (ico.org.uk). In the EEA, it is the data protection authority in your country of residence, work, or where the issue arose. We would appreciate the chance to address your concern first.

Members may also ask to be excluded from our quality monitoring entirely; this opt-out is honored before any processing occurs, including the automated quality rating. If you request deletion of your data, we also scramble the coded reference used in our measurements, so historical quality data can no longer be connected to you.

11. Your rights in the United States

You may opt out of promotional emails at any time using the "unsubscribe" link in any message or by contacting us. Transactional messages, such as receipts, subscription reminders, price-change notices, cancellation confirmations and messages about your membership or program participation, are not subject to opt-out. Residents of certain US states may have additional rights to access, correct, or delete personal information, or to opt out of certain processing. To exercise these rights, contact privacy@internality.org.

12. Cookies and similar technologies

The Site uses a small number of cookies and similar technologies. Non-essential analytics and marketing technologies are only used where permitted under our consent model. Full details, including how to change your preferences, are in our Cookie Policy.

13. Data security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. Our infrastructure providers maintain recognized security certifications. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

14. Children

The Site is directed to business and professional audiences and is not intended for children. We do not knowingly collect personal information from children under the age of 13, or under the higher minimum age that applies where you live. If you believe a child has provided us with personal information, contact us and we will take steps to delete it.

15. Third-party links

The Site may link to third-party websites and services we do not operate. We are not responsible for their privacy practices. Please review their policies before providing personal information.

16. Changes to this policy

We may update this policy to reflect changes in our practices or the law. We will post the updated version here with a revised date and, where appropriate, provide additional notice. Please review this page periodically.

17. Contact us

Questions, concerns, or requests about this policy or your personal information: Internality, hello@internality.org or privacy@internality.org. Questions about gifts, subscriptions or payments: giving@internality.org.