Last updated: January 31, 2023
Table of Contents
- Information We Collect
- How We Collect Information
- Cookies and Interest-Based Advertising
- How We Use and Disclose Information
- Data Security
- Children’s Privacy
- Additional State Privacy Rights
- Contact Us
Conflict Between This Policy and Local Laws and Regulations
Information We Collect
We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
- Identifiers such as name, address, email addresses, phone numbers, JadeTrack login information;
- Demographic information such as the language(s) you speak, information related to co-owners or other persons living at the property, household income;
- Internet or other electronic network activity information such as browsing/search history, IP address, data collected by cookies and similar technologies, device information such as device IDs, specifications, and operating system;
- Geolocation data such as non-precise geographic location indicators from mobile devices, websites, service addresses, signed contracts, photos;
- Audio, electronic, visual, or similar information such as call recordings, chat transcripts, email correspondence, testimonials;
- Professional/employment information such as employer, occupation;
- Inferences drawn from other Personal Information or data that relate to your preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, including credit reports and scores; and
- Personal information as described in Cal. Civ. Code § 1798.80(e) to the extent collected under another category of Personal Information above.
Some of the Personal Information listed above may be considered Sensitive Personal Information under relevant privacy laws. This includes JadeTrack account login credentials. Each type of Sensitive Personal Information may overlap with a category of Personal Information listed above.
The type of Personal Information we collect about you may vary based on how you use our Sites and/or Services and your relationship with us.
Usage Data and Site Activity
We automatically collect information in connection with the actions you take on our Sites (“Usage Data”). For example, each time you use our Sites, we may collect the type of web browser you use, the type of device you use, your device ID, your operating system and version, your IP address, your internet service provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. Among other things, this data helps us estimate our audience size and usage patterns, recognize you when you return to our Sites, store information about your preferences, customize our Sites according to your interests, and speed up your searches. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the categories of Identifiers or Internet or other electronic network information, as appropriate. If this information is not capable of being individually associated with you, we treat it as Usage Data.
We may record calls and retain the content of text messages, chat transcripts, or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
How We Collect Information
We may ask you to provide us with Personal Information when you communicate with us online or offline, including web forms, events, surveys, and marketing or promotional programs. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Sites or Services or we may not be able to fulfill your requested interaction. We may also capture your contact information, such as phone numbers and email addresses, when you contact us.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as data brokers, marketing and sales agencies or partners, analytics firms, government agencies, utilities, other customers or consumers, and credit reporting agencies.
Cookies and Interest-Based Advertising
Cookies and Automated Tools
We use the following types of cookies:
- Strictly Necessary: These cookies are essential to operate the Sites and provide you with services you have requested.
- Functional: These cookies enable certain features or non-essential functionality on our Sites. For example, we might use these cookies to recognize you and remember your preferences or settings when you return to our Sites so we can provide you with a more personalized experience.
- Advertising Cookies: These cookies allow us and third parties to learn more about you, including your use of our Sites and other websites, and advertise products or services that might interest you as further indicated below.
- Analytics Cookies: These cookies help us and third parties understand how our Sites are working and who is visiting our Sites.
We and third parties also use tools that enables us to track certain aspects of a user’s visit to our Sites. This technology helps us better manage content on our Sites by informing us what content is effective, how consumers engage with our Sites, and how consumers arrive at and/or depart from our Sites. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether a user views a web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.
Information from Advertisements
If you arrive at our Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
Social Media Widgets
Our Sites may include social media features, such as the Facebook, YouTube, Instagram, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our Sites as well as other Personal Information. A cookie may be set to ensure that these features properly function. These companies’ privacy policies govern your interactions with these features and you should review the relevant privacy policies before interacting with these features.
How We Use and Disclose Information
We may use Personal Information for business purposes, such as to:
- Account creation, fulfillment, servicing and customer support: to process applications, create customer accounts, allow customers to create online accounts and profiles, provide goods or services, keep customers informed about the status of their products and services, engage in general customer service operations, provide newsletters, announcements, service bulletins and other information, or to otherwise fulfill the purpose for which you provide your information;
- Marketing and market research: to send communications and offers for our or third parties’ products and services, including offers based on consumers’ interests, personal and business characteristics and location, perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal information;
- Customer communications and interactions: to administer surveys, polls, sweepstakes, contests, promotional events, or to otherwise communication and interact with customers and consumers;
- Website use and analytics: to provide you with access to and use of our Sites and Services, analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data;
- Eligibility and pricing: to determine if consumers are eligible for certain products, services, or offers and the pricing related to such offers;
- Product research: to conduct research and analysis for maintaining, protecting, and developing services, increase and maintain the safety of our products and services, and prevent misuse;
- Business operations: to evaluate, develop, and improve business operations, products and services offered, carry out our obligations and enforce our rights arising from any contracts entered into between you and us, perform business administration and other normal business activities;
- Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others; and
- Information security and fraud prevention: to operate information security and anti-fraud programs.
We use Sensitive Personal Information as follows:
- JadeTrack account login information – to permit access to customers’ online accounts, and in connection with our security and anti-fraud programs.
We may also use Personal Information and Sensitive Personal Information as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws. We only use Sensitive Personal Information related to California residents for purposes permitted by California Privacy Rights Act regulations.
Reviews and Testimonials
If you provide a review or testimonial, we may post it publicly on our Sites or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
If you do not want us to use your Personal Information for certain marketing purposes, you may take advantage of applicable opt-out options such as checking the relevant box located on the form on which we collect your information, adjusting your user preferences in your account profile, or opting out of promotional emails through an unsubscribe link or by emailing us at email@example.com.
We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of service providers we use include:
- Fulfillment and account servicing vendors, which help us provide products, services and information to you, service your account or benefits, and collect past due balances;
- Payment processors, which help us to accept and process the payments for our products/services to you;
- Marketing and communications vendors, which help us market our products/services to you, conduct promotions, surveys, and other outreach campaigns;
- Research and development vendors, which help us develop and improve our products and services;
- Consumer reporting agencies, which help us evaluate your eligibility for certain products or financing options;
- Data and business analytics vendors, which help us collect, analyze, and improve the accuracy of our data (including Personal Information);
- IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;
- Professional service firms, which provide accounting, legal, auditing, and other professional services; and
- General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.
We require each Service Provider to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information we provide to them other than as specified by us.
In the past twelve months we may have disclosed each category of Personal Information that we collect (listed above) to Service Providers.
Third-Party Selling and Sharing
We may sell or share (for targeted or cross-context behavioral advertising purposes) your Personal Information with other companies who do not provide services to us (“Third Parties”), including affiliates, advertising, social media, and analytics companies, data brokers, and other companies that sell consumer products or services. These companies may use your Personal Information for their everyday business purposes, including marketing, customer service, fulfillment, and related purposes. In the past 12 months we sold and shared Personal Information as follows:
- Advertising, social media, and analytics companies – we sold and shared Identifiers and Internet or other electronic network activity information for the purposes described above. These companies may use your Personal Information for additional purposes outlined in their privacy policies.
Other Third-Party Disclosures
We may occasionally disclose your Personal Information to Third Parties, for purposes such as:
- To comply with the law;
- To respond to legal requests (including court orders, investigative demands and subpoenas) if, in our discretion, we believe it is necessary or appropriate;
- To prevent or stop any illegal, unethical, or legally actionable activity;
- To protect the safety, property, or rights of ourselves, consumers, or any other third party;
- If we are merged, acquired, or sold, or in the event of a divestiture, restructuring, reorganization, or transfer of some or all of our assets and the disclosure is necessary to complete the transaction;
- To businesses controlling, controlled by, or under common control with us; and
- For additional purposes with your consent where such consent is required by law.
In the past twelve months, we did not disclose any Personal Information to any third party (excludes service providers).
Links and Other Websites
Our Sites may contain links to third party websites, including social media platforms. Please be aware that if you access these links, you will be leaving our site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ (without obligation) commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use.
The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Sites, you must keep this password confidential. We ask that you not share your password with anyone and urge you to be careful about giving out information in public areas of the Sites, like message boards. The information you share in public areas may be viewed by any user of the Sites.
Even with data security safeguards in place, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.
Our Sites are not intended for children under 16 years of age. No one under age 18 should provide Personal Information to us or on the Sites. We do not knowingly collect, sell, share, or disclose Personal Information from children under 16. If you are under 16, do not use or provide any information on our Sites. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us using the contact information listed below.
Additional State Privacy Rights
If you are a resident of California, you may have additional rights to access and control your Personal Information. Exemptions may apply. Consumer privacy rights for residents of these states include:
Right to Opt-Out from the Sale or Sharing of Personal Information
You have the right to direct us not to sell or share (for targeted or cross-context behavioral advertising purposes) your Personal Information to Third Parties. We will process requests within 15 business days, subject to any applicable exceptions and extensions permitted by law.
Our Sites also recognize and process Global Privacy Control (GPC) signals. If we are able to reasonably associate a GPC signal with an identifiable consumer, we will treat it as a request to opt-out of the sale or sharing of that consumer’s Personal Information as if the consumer made the request using a method below. If we are not able to reasonably associate a GPC signal with an identifiable consumer, we will treat it as a request to opt-out of the sale or sharing of that user’s Personal Information collected while the signal is present.
Right to Know
You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which we collected your Personal Information; (iii) the business or commercial purpose for which we collected your Personal Information; and (iv) the categories of Third Parties with whom we sold, shared, or disclosed your Personal Information. including the categories of Personal Information sold, share, or disclosed to each and the purposes for doing so. We are not permitted to provide access to specific pieces of Personal Information that creates a high risk of potential harm from disclosure to an unauthorized person such as social security numbers and driver’s license numbers. To protect consumers’ Personal Information, you must provide required information and/or documentation to verify your identity. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law. To prevent unauthorized individuals from making deletion requests, you must provide required information and/or documentation to verify your identity. We will retain a copy of your deletion request for at least two years as required by law.
Right to Correct
You have the right to request that we correct inaccurate Personal Information we maintain about you. After you request to correct inaccurate Personal Information, we will provide instructions for you to provide us with optional documentation to support your request and we will consider it. We may decline to correct your Personal Information if a legal exemption applies such as if we determine that your request is fraudulent or abusive or if we determine, based on the totality of the circumstances, that your correction is more likely inaccurate than accurate. We may decide to delete your allegedly inaccurate Personal Information instead of correcting it. We will process verified requests within 45 days, subject to any applicable exceptions and extensions permitted by law.
If you only wish to update your contact information or other Personal Information rather than disputing its accuracy, please make the changes directly in your account.
Right to Appeal
You have the right to appeal our decision to deny, in full or in part, one or more of your privacy requests. We will process appeal requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law. If we deny your appeal, we will provide you with a written explanation of the reasons for our decision. If you are not satisfied with our explanation for the denial of your appeal, you may have an additional right under certain laws to contact your state Attorney General to submit a complaint about the appeal results. In such case, we will provide you with instructions for doing so.
Submitting a Request
If you are a California resident and would like to exercise your rights, you may submit a request emailing us at firstname.lastname@example.org, or through our online privacy request form.
If you are an authorized agent submitting a request for another consumer, you must provide a copy of a lawful power of attorney or written authorization from the Consumer (along with proof of your identity). You will be provided options on how to provide this documentation after submitting the request. We may contact you or the Consumer on whose behalf you claim to act to verify your authorization.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “do not track” signals.