Privacy, Security, Retention and Destruction Policy

1. Purpose

Alchemister, LLC d/b/a Men’s Initiation Weekend (“MIW”) is committed to protecting the privacy, confidentiality, and security of personal information provided by its members, participants, volunteers, guests, parents, guardians, and emergency contacts.

MIW may collect limited information concerning allergies, medical sensitivities, emergency contacts, and related emergency instructions when reasonably necessary to protect the health and safety of persons participating in MIW activities and volunteers.

The purpose of this Policy is to establish reasonable procedures for collecting, accessing, using, storing, disclosing, retaining, and securely destroying that information in accordance with applicable Vermont law and sound privacy and information-security practices.

2. Information Covered by this Policy

This Policy applies to information maintained electronically or in paper form concerning:

• food, medication, insect, environmental, or other allergies;
• the nature or severity of an allergy when voluntarily provided;
• emergency medications or emergency instructions voluntarily provided to MIW;
• dietary or activity restrictions related to an allergy or medical sensitivity;
• the name and telephone number of an emergency contact;
• the emergency contact’s relationship to the member or participant;
• parent or guardian contact information;
• other limited health or emergency information reasonably necessary for MIW to respond appropriately to an emergency; and
• any other personally identifying information maintained in connection with these records.

Collectively, this information is referred to in this Policy as “Confidential Emergency Information.”

3. Data Minimization

MIW will collect only the Confidential Emergency Information that it reasonably determines is useful or necessary for participant and volunteer safety, emergency response, or administration of MIW activities.

MIW will not request Social Security numbers, health-insurance information, detailed medical histories, medical records, or unrelated medical information as part of its ordinary allergy and emergency-contact process.

Members, volunteers and participants should provide only information reasonably necessary to enable MIW to respond appropriately in an emergency.

4. Purpose and Permitted Use

Confidential Emergency Information shall be used only for legitimate MIW purposes, including:

• responding to an actual or reasonably anticipated medical or safety emergency;
• informing appropriate MIW personnel of an allergy or restriction when necessary to protect a participant;
• contacting a designated emergency contact, parent, or guardian;
• providing relevant information to emergency medical personnel, first responders, or health-care providers when reasonably necessary in an emergency;
• administering MIW activities safely; and
• complying with applicable law.

MIW will not sell Confidential Emergency Information or use it for advertising, marketing, fundraising, or other unrelated purposes.

5. Access — Need-to-Know Basis

Access to Confidential Emergency Information shall be limited to persons who reasonably require the information to perform MIW responsibilities or respond to an emergency.

Depending upon MIW’s operations, authorized persons may include:

• MIW’s manager(s) or designated administrator;
• activity leaders or supervisors responsible for the affected participant;
• persons designated to respond to medical or safety emergencies; and
• other persons specifically authorized by MIW management when access is reasonably necessary.

Access shall not be provided merely because an individual is a member of MIW, serves on a committee, or otherwise has access to general MIW records.

Persons receiving Confidential Emergency Information shall be instructed to maintain its confidentiality and to use it only for its intended purpose.

6. Disclosure in an Emergency

Nothing in this Policy is intended to prevent the prompt disclosure of information when reasonably necessary to protect the health or safety of a person.

In an emergency, relevant information may be disclosed to:

• emergency medical technicians;
• ambulance personnel;
• firefighters;
• police or other first responders;
• physicians, nurses, hospitals, or other health-care providers;
• a designated emergency contact;
• a parent or legal guardian; or
• another person when disclosure is reasonably believed necessary to protect the health or safety of the affected individual.

Only information reasonably relevant to the circumstances should be disclosed.

7. Paper Records

Paper records containing Confidential Emergency Information shall:

• be kept in a locked cabinet, locked office, or other location not ordinarily accessible to members, guests, or unauthorized persons;
• not be left unattended in public or common areas;
• not be posted on publicly accessible bulletin boards or similar locations; and
• be returned promptly to secure storage after use.

If a temporary allergy or emergency list is reasonably necessary for an activity, access shall be limited to the persons responsible for participant safety, and the list shall be returned or securely destroyed when no longer needed.

Any and all paper records shall only be retained pursuant to the requirements and conditions contained herein, and when no longer necessary and can are no longer required to be retained for any reason stated herein, shall promptly be securely destroyed.

8. Electronic Records

Electronic records containing Confidential Emergency Information shall be maintained using reasonable security safeguards appropriate for a small organization.

At a minimum, MIW shall:

• protect accounts and devices containing the information with passwords or equivalent access controls;
• limit access to authorized persons;
• avoid storing Confidential Emergency Information on publicly accessible drives, websites, or shared folders;
• use reputable service providers and reasonable security settings when cloud storage or membership-management systems are used;
• promptly discontinue access when an authorized person’s responsibilities end; and
• maintain reasonable device and software security practices.

Where reasonably practicable, multi-factor authentication should be used for accounts containing Confidential Emergency Information.

9. Email, Text Messages, and Informal Communications

Confidential Emergency Information should not ordinarily be distributed through broad email lists, group text messages, social-media groups, or other communications accessible to persons who do not have a need to know the information.

When emergency information must be transmitted electronically, MIW shall make reasonable efforts to limit the recipients and the amount of information transmitted.

10. Accuracy and Updates

Members, participants, volunteers, parents, or guardians are responsible for notifying MIW when allergy or emergency-contact information changes.

MIW should periodically provide a reasonable opportunity to review and update emergency information, particularly at the beginning of a new activity or weekend event.

11. Retention

MIW will retain Confidential Emergency Information only for as long as reasonably necessary for the purpose for which it was collected or as otherwise required by law.

Unless a longer period is reasonably necessary because of an accident, incident, dispute, insurance matter, legal claim, or legal requirement:

Active participants: Allergy and emergency-contact information may be retained while the individual remains an active participant or volunteer and should be periodically updated.

Former participants: Routine allergy and emergency-contact information should ordinarily be securely destroyed within one year after the end of the individual’s participation or volunteer service, unless MIW determines that continued retention is reasonably necessary.

Incident records: If information becomes part of an accident, injury, emergency, insurance, or incident report, the relevant information may be retained with that record according to MIW’s applicable record-retention requirements.

MIW shall suspend routine destruction of relevant information if it reasonably anticipates litigation, an insurance claim, governmental inquiry, or other legal proceeding for which the information may be relevant.

12. Secure Destruction

When Confidential Emergency Information is no longer required to be retained, MIW shall take reasonable steps to destroy it so that the personal information cannot practicably be read, reconstructed, or recovered.

Appropriate destruction methods include:

Paper records: cross-cut shredding, secure commercial shredding, pulverizing, or another method that renders the information unreadable.

Electronic records: secure deletion or erasure using a method reasonably designed to make the information inaccessible or unrecoverable, taking into account the nature of the device or system.

Simply placing intact confidential documents in ordinary trash or recycling is prohibited.

When an outside records-destruction company is used, MIW should use a reputable provider that maintains reasonable procedures designed to prevent unauthorized access to records during collection, transportation, and destruction.

13. Lost, Stolen, or Improperly Disclosed Information

Any MIW officer, manager, employee, volunteer, or other authorized person who becomes aware that Confidential Emergency Information may have been:

• lost;
• stolen;
• accessed by an unauthorized person;
• emailed or otherwise transmitted to an unintended recipient;
• publicly disclosed;
• improperly disposed of; or
• otherwise compromised

shall promptly report the matter to the MIW Leadership Team.

MIW shall promptly investigate the circumstances, take reasonable measures to contain and correct the problem, determine what information and individuals were affected, and determine whether notification or other action is required under applicable Vermont or federal law.

No person shall attempt to conceal a suspected loss or unauthorized disclosure of Confidential Emergency Information.

14. Service Providers

If MIW permits a third-party service provider to maintain Confidential Emergency Information on its behalf, MIW shall use reasonable care in selecting the provider and should require the provider to maintain appropriate confidentiality, security, and disposal practices.

MIW should provide third parties only the information reasonably necessary to perform the requested service.

15. Confidentiality Obligations

MIW officers, managers, employees, volunteers, committee members, and other persons granted access to Confidential Emergency Information shall:

• access the information only when reasonably necessary;
• use the information only for authorized MIW purposes;
• refrain from discussing the information with persons who do not have a need to know;
• protect paper and electronic copies against unauthorized access;
• promptly report suspected losses or unauthorized disclosures; and
• return or securely destroy MIW information when their responsibilities end.

16. Requests to Correct or Remove Information

A member, volunteer, participant, parent, or guardian may request that allergy or emergency-contact information be corrected or updated.

A request for deletion will be honored when the information is no longer reasonably necessary for MIW operations, safety, legal compliance, insurance, or the preservation of records relating to an incident or potential claim.

17. No Public Disclosure

MIW will not publish or make publicly available a person’s Confidential Emergency Information except with appropriate authorization or when disclosure is required by law.

The existence of a medical emergency does not authorize broader disclosure than is reasonably necessary to address the emergency.

18. Responsibility for Administration

MIW shall designate the MIW Leadership Team to administer this Policy.

The designated person shall be responsible for:

• maintaining appropriate access controls;
• periodically reviewing stored information;
• coordinating secure destruction;
• responding to reports of suspected unauthorized access or disclosure; and
• reviewing this Policy periodically for changes in MIW’s operations or applicable law.

For a small organization, these responsibilities may be performed by MIW’s Manager, President, Secretary, or another designated officer and do not require the creation of a separate staff position.

19. Vermont Law

This Policy is intended to implement reasonable privacy, security, retention, and destruction practices consistent with applicable Vermont law, including, where applicable, Vermont’s laws concerning the protection of personal information, security-breach notification, and secure destruction of records.

MIW shall comply with applicable law if a legal requirement imposes a greater obligation than this Policy.

20. Annual Review

MIW shall review this Policy periodically, and preferably at least annually, to determine whether:

• MIW is collecting information it no longer needs;
• access remains appropriately limited;
• electronic and physical safeguards remain reasonable;
• records eligible for destruction have been securely destroyed; and
• changes in law or MIW operations require revisions to this Policy.

21. Questions and Privacy Contact

Questions, requests for correction, or reports concerning the privacy or security of Confidential Emergency Information should be directed to:

Privacy Contact: MIW Leadership Team
Entity: Alchemister, LLC d/b/a Men’s Initiation Weekend
Email: mens.initiation.weekend@gmail.com

Adopted by Alchemister, LLC d/b/a Men’s Initiation Weekend on September 16, 2026.

Website Addendum: Registration Site, Payments and Cookies

The Policy above governs allergy, medical and emergency contact information. This addendum describes how Alchemister LLC handles the other information collected through the Men’s Initiation Weekend website, registration process, and related communications.

Information you provide

When you register, we collect your name, email, phone number, address, age, occupation, relationship status, number of children, signature, and registration answers. We also collect sponsor and emergency-contact details. Please provide another person’s information only with their permission.

Medical information and allergies

The registration form asks about medical or psychological concerns and allergies, including food allergies, to help the event team plan participation, accommodations, and safety. Please provide relevant information only; do not include unrelated medical records. These answers are Confidential Emergency Information under the Policy above and are available only to authorized registration leadership through participant records and reports.

How information is used

We use registration information to administer the event, communicate with participants and sponsors, process registrations and payments, plan event operations, and respond to questions. Technical information may also be used to secure the website, prevent abuse, and troubleshoot problems.

Payments

Stripe processes payments through its secure payment interface. Our website receives payment references and status information, but does not receive your full card number or security code. Stripe and any payment method you choose handle payment information under their own terms and privacy policies. See Stripe’s Privacy Policy.

Who receives information

Information is shared with authorized event personnel as needed for registration and event operations, and with service providers supporting website hosting, security, communications, and payments. The Site Manager report includes participant name, phone, email, age, sponsor name, and sponsor phone; it excludes medical answers and internal notes. Information may also be disclosed when required by law or reasonably necessary to address a safety or security issue.

Cookies and technical information

The website uses session and security technology to support sign-in, forms, and checkout. Hosting and security services may record information such as IP address, browser details, requested pages, timestamps, and errors. Payment services may use additional cookies or similar technology. Blocking essential cookies can prevent registration or payment from working.

Retention and security

Registration information is retained for event administration, support, and applicable accounting, legal, and recordkeeping needs. It is stored encrypted at rest, and access controls and other safeguards help protect it, but no online service can guarantee absolute security. Contact us to discuss correction or deletion; some records may need to be retained, and backup copies may take additional time to expire.

Your choices and questions

You may ask about your information or request access, correction, or deletion by contacting Alchemister LLC at mens.initiation.weekend@gmail.com. We may need to verify your identity before responding. Rights and exceptions can vary depending on applicable law.

Adults only

This event is intended for adults. The registration form asks participants to confirm that they will be at least 21 by the event’s start date. If you believe a child has supplied personal information, contact us.

Changes to this page

We may update this page as our website or practices change. Material changes will be communicated as appropriate.