NSGF-301
NORTHSTAR ONBOARDTM
Privacy Policy
Raynbo Development, LLC
1. Purpose
Raynbo Development LLC is committed to protecting the privacy, confidentiality, integrity, and appropriate use of information entrusted to NorthStar OnboardTM.
This Privacy Policy describes how information is collected, used, disclosed, retained, protected, and managed in connection with the NorthStar OnboardTM platform, and it explains the different roles Raynbo Development LLC may hold with respect to that information (see Section 2).
This policy supports the NorthStar Governance FrameworkTM and reflects our commitment to responsible governance, transparency, and stewardship.
2. Our Role: Service Provider and Controller
Raynbo Development LLC may act in either of two roles depending on the context in which information is processed.
Service Provider (Processor)
When a customer organization uses NorthStar OnboardTM to govern access for its populations, the customer organization determines what personal information is collected, the purposes for which it is processed, and who may access it. In this context, the customer organization is the controller of that information, and Raynbo Development LLC processes it as a service provider on the customer’s behalf, under contract and under the customer’s instructions. The customer organization’s own privacy notice governs its relationship with the individuals whose information it submits. Processing in this role is further described in the Data Processing Agreement (NSGF-305).
Controller
When individuals interact directly with Raynbo Development LLC — for example, by visiting our website, inquiring about our services, subscribing to communications, or contacting support — Raynbo Development LLC determines the purposes, means of processing, and acts as the controller. This Privacy Policy governs that processing directly.
3. Scope
This Privacy Policy applies to information processed in connection with NorthStar OnboardTM, including information relating to:
● Customer organizations and their authorized administrators and users.
● Vendor Personnel, including hired law-enforcement and security-agency personnel as configured sub-types.
● Visitors.
● Volunteers.
● Employee (Workforce Personnel).
● Applicants and other individuals whose information is processed through the platform.
This policy applies to information processed through:
● The NorthStar OnboardTM platform.
● Customer onboarding activities.
● Platform administration.
● Customer support.
● Training activities.
● Platform communications and the Raynbo Development LLC website.
4. Privacy Principles
Raynbo Development LLC manages information according to the following principles:
● Transparency.
● Accountability.
● Data minimization.
● Accuracy.
● Appropriate security.
● Purpose limitation.
● Human oversight of authorization decisions. ● Responsible stewardship.
● Compliance with applicable laws.
● Continuous improvement.
5. Information Raynbo Development Collect
Depending upon customer configuration and organizational requirements, NorthStar OnboardTM may process information including the categories below.
Identity Information
● Full name.
● Organization.
● Job title.
● Contact information.
● Government-issued identification information (when required by the customer organization).
● Last four social security numbers.
● Employee, vendor, or personnel identification numbers.
Business Information
● Company information.
● Contract information.
● Procurement information.
● Insurance documentation.
● Professional licenses.
● Certifications.
● Organizational affiliations.
Background Screening and Credentialing Information
Where required by the customer organization, the platform may capture the completion status of background screening and fingerprinting requirements as a self-certification (for example, Complete or Outstanding), along with related credentialing records.
Important: NorthStar OnboardTM records self-certification status only. The platform does not collect, process, or store biometric identifiers, including fingerprint images or scans. Background checks and fingerprinting are conducted by the customer organization or its authorized third parties outside the platform.
Governance Information
● Registration status.
● Approval history.
● Credential status.
● Authorization history.
● Required documentation.
● Compliance records.
● Training completion.
● Governance notes.
Technical Information
● Username.
● Login and authentication activity.
● Device information.
● Browser information.
● Internet Protocol (IP) address.
● System activity logs.
Customer Support Information
When users request assistance, Raynbo Development LLC may process information necessary to investigate and resolve support requests.
Sensitive Information
Certain information the platform may process — such as government-issued identification information or, where required by the customer, the last four digits of a Social Security Number for identity verification — may be considered sensitive personal information under applicable privacy laws. Where such information is processed, it is handled only for the identity-verification and governance purposes directed by the customer organization, and it is protected using the safeguards described in Section 10.
6. How Information Is Collected
Information may be collected through:
● User registration.
● Customer administrators.
● Authorized organizational representatives.
● File uploads.
● Customer integrations.
● User communications.
● Platform activity.
● Customer support interactions.
Customer organizations remain responsible for ensuring they have appropriate authority to collect and submit information to NorthStar OnboardTM.
7. How Information Is Used
Information is used to support governance activities, including:
● User registration.
● Identity verification.
● Credential management.
● Authorization workflows.
● Compliance verification.
● Customer administration.
● Platform security.
● Customer support.
● Reporting.
● Audit activities.
● Platform improvement.
● Legal and regulatory compliance.
Information is processed only for legitimate business and governance purposes. Raynbo Development LLC may also create and use de-identified or aggregated information (which cannot reasonably be used to identify an individual) to operate, secure, evaluate, and improve the platform. Raynbo Development LLC does not attempt to re-identify de-identified information except as permitted by law to test its de- identification measures.
8. Automated Decision-Making and Human Oversight
NorthStar OnboardTM is designed so that authorization decisions require human review and approval. The platform may organize, calculate, or surface information to support a reviewer, but credentials and authorizations are issued, renewed, suspended, or revoked only by authorized human reviewers within the customer organization.
The platform does not automatically issue or automatically renew credentials, and it does not make legally significant decisions about individuals through solely automated means without human involvement.
9. Information Sharing
Raynbo Development LLC does not sell personal information. Raynbo Development LLC does not use personal information for third-party advertising and does not share personal information for cross- context behavioral advertising.
Information may be shared only when appropriate to:
● Provide contracted services.
● Support authorized customer activities.
● Comply with applicable law.
● Respond to lawful governmental requests.
● Protect the security of the platform.
● Protect the rights, safety, or property of Raynbo Development LLC, customer organizations, or
users.
● Support approved service providers (subprocessors) operating under appropriate confidentiality
and data-protection obligations.
Approved service providers that process information on our behalf are bound by contractual obligations
consistent with this policy and the Data Processing Agreement (NSGF-305). Customer organizations determine which authorized personnel may access information within their own organizational environment.
10. Information Security
Raynbo Development LLC employs administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, misuse, or destruction.
Security measures may include:
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Encryption.
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Authentication controls. Role-based access.
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Audit logging.
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Secure hosting.
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Security monitoring.
Backup and recovery capabilities. Incident response procedures.
In the event of a security incident affecting personal information, Raynbo Development LLC will notify affected customer organizations in accordance with applicable law and contractual commitments and will reasonably support customers in meeting their own notification obligations.
Additional security standards are established within the NorthStar Governance FrameworkTM (see the 400 Series).
11. Data Retention
Information is retained only as long as necessary to:
● Provide contracted services.
● Support governance activities.
● Meet legal or regulatory obligations.
● Satisfy customer contractual requirements.
● Support audit and records-management requirements.
Where Raynbo Development LLC processes information as a service provider, retention follows the customer organization’s instructions and the applicable agreement. Detailed retention schedules are established in the NorthStar Data Retention Standard (600 Series).
12. Your Privacy Rights
Subject to applicable law, individuals may have the ability to request:
● Access to their personal information.
● Correction of inaccurate information.
● Updates to personal information.
● Deletion where legally permissible.
● Restrictions on certain processing activities.
Because information processed through NorthStar OnboardTM is generally managed by the customer
organization, individuals should ordinarily direct rights requests to the customer organization that manages their access.
Where Raynbo Development LLC acts as a service provider, we will reasonably support the customer organization in responding to verified requests.
Whereas Raynbo Development LLC acts as the controller (for example, for website visitors and direct inquiries), individuals may submit requests using the contact details in Section 19. Raynbo Development LLC will not discriminate or retaliate against individuals for exercising their privacy rights. Certain requests may be subject to organizational policies, contractual obligations, legal requirements, or applicable regulations, and may require verification of identity.
13. Customer Responsibilities
Customer organizations remain responsible for:
● Determining what information is collected.
● Obtaining required notices or consents.
● Establishing lawful purposes for processing.
● Managing organizational access.
● Maintaining data accuracy.
● Responding to individual rights requests where applicable.
NorthStar OnboardTM supports governance activities but does not assume the customer organization’s legal responsibilities regarding privacy compliance.
14. Education Sector, FERPA, and Student Data
Where the customer organization is an educational agency or institution, the customer organization remains responsible for compliance with the Family Educational Rights and Privacy Act (FERPA) and any applicable state student-data-privacy laws. To the extent Raynbo Development LLC processes information under a customer’s direction as a “school official” with a legitimate educational interest, it does so only as permitted by the customer’s agreement and does not use such information for unauthorized purposes.
NorthStar OnboardTM is designed to govern organizational and adult populations — such as Vendor Personnel, Visitors, Volunteers, and Employee (Workforce Personnel) — and is not a student information system.
15. Cookies and Similar Technologies
NorthStar OnboardTM may use cookies, session technologies, and similar technical tools necessary to:
● Authenticate users.
● Maintain secure sessions.
● Improve platform performance.
● Support system administration.
● Enhance the user experience.
These technologies are used for authentication, security, and platform functionality. NorthStar OnboardTM does not use cookies for third-party advertising and does not track users across unaffiliated third-party websites. Where required by applicable law, additional notice or consent will be provided.
16. Children’s Information
NorthStar OnboardTM is designed for organizational use and is not intended for direct consumer use by children. Raynbo Development LLC does not knowingly collect personal information directly from children for consumer purposes.
Where a governed individual may be a minor (for example, a minor volunteer or visitor), the customer organization remains responsible for ensuring that appropriate authority or consent exists before information relating to that individual is entered into the platform.
17. International Use
NorthStar OnboardTM is intended primarily for organizations operating within the United States. Organizations operating in other jurisdictions remain responsible for complying with applicable privacy and data-protection laws.
18. Changes to This Privacy Policy
Raynbo Development LLC may revise this Privacy Policy periodically. The current version, together with its effective date, will be made available through the platform or the Raynbo Development LLC website. Material revisions will be communicated to customer organizations through the platform, customer notifications, or other appropriate methods.
The terms governing a customer organization’s use of NorthStar OnboardTM are set out in the applicable customer agreement. For individuals who interact directly with Raynbo Development LLC, continued use following the effective date indicates awareness of the updated Privacy Policy.
19. Contact Information
Questions or requests regarding this Privacy Policy may be directed to:
Privacy Email: privacy@raynbodevelopment.com
20. Related Framework Documents
● NSGF-300 — Terms of Use
● NSGF-400 Series — Information Security Standards
● NSGF-600 Series — Data Retention Standards
NorthStar Commitment. One Platform. One Process. One Credential Standard.