*Last modified June 29, 2020
2. INFORMATION WE COLLECT ABOUT YOU.
When you use or access any of the Website Services, we may collect contact information, such as name, e-mail address, phone number, mailing address, state and country residence, and telephone number. When you use or access certain Website Services, we may collect additional personal information as follows:
• When you use or access www.jenzabar.com, we may collect personal information, such as the following:
o Your preferences, areas of interest, and business needs related to the Services.
o Information you submit when you register for or log into our Services, such as authentication credentials.
o Educational information or professional or employment-related information, such as your educational institution, job title, or information you submit in connection with an application for employment, such as your resume.
o Registration information associated with our events, webinars, and products and Services demos.
• When you use or access www.myjenzabar.net, we may collect information you submit or that we otherwise receive in connection with client support requests.
We may collect information at live events, such as when we collect your contact information at a trade-show event or our annual convention. We may also collect information related to our Services that you send through our listserv or comments or other information we receive when you interact with our social media accounts, such as Twitter, Vimeo, and Facebook.
When you use the Services, we may automatically collect information, such as the following:
• Your device type, manufacturer, operating system name, and operating system version.
• Name, version, and other information about the online services and software you are using in connection with the Services (such as mobile apps).
• Your mobile device identifier (such as Android UDID and iOS UUID).
• The Internet protocol (IP) address your device uses to access the Internet.
• Your geo-location.
• Other information, such as usage analytics data.
We may use the following automated technology to collect information in connection with the Services:
• Browser and Device Information: Certain information is collected by most browsers or automatically through your device, such as your device type, operating system name and version, device manufacturer and model, Internet browser type and version and the name and version of the online services (such as apps) you are using. We use this information to ensure that the Services function properly.
• IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Website Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications, and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems, and administering our Services. We may also derive your approximate location from your IP address to understand from what regions of the world our website visitors come.
With respect to personal information that we collect or receive from or on behalf of our clients as a result of the Client Services we provide to them, we act as the “processor” of such personal information. In those cases, we collect, receive, use, and disclose personal information at the direction of our clients to, for example, enable our clients to manage recruitment and enrollment, learning, financial aid, advancement, retention, and similar relationship and operational management activities. The types of information we collect or receive may include those described above, as well as other types of information that we collect or receive as dictated by our clients, including authentication credentials; government- or institution-issued identification numbers, such as Social Security numbers, state-issued identification numbers, and student identification numbers; online browsing activity, application usage, and other information we access or receive in connection with providing support services; and information that we host on behalf of our clients. The manner in which we use and disclose that information is subject to our clients’ direction, but will generally align with the descriptions provided below in the sections on How We Use Your Information and Disclosure of Your information.
3. HOW WE USE YOUR INFORMATION. We may use personal information that we collect or receive about you for purposes including the following:
• Providing you with the Services and responding to your requests.
• Completing transactions and performing our contractual obligations.
• Providing our clients with the Services, including by providing client support and hosting Services.
• Communicating with you and providing you with information that you request from us or which we feel may interest you, including newsletters, white papers, company updates, survey reports, invitations to events, and otherwise marketing our products and Services.
• To create aggregate or deidentified data.
• Conducting demos of our products and Services.
• Understanding how you and our clients use our Services.
• Improving our Services.
• Calculating user levels and diagnosing server problems.
• To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our Services.
• Determining your approximate location.
• Customizing our Services according to your individual interests and preferences.
• Analyze and enhancing our marketing communications and strategies.
• Storing information about your preferences and recognizing you when you use the Services.
• Notifying you when updates to the Services are available and of changes to the Services.
• For our internal business operations, such as operating our business, evaluating and improving the effectiveness of our operations, including our Services and marketing efforts, conducting research and analysis, developing new services, and performing other internal business operations, including as described elsewhere in this Policy.
• Protecting the rights, property, or safety of us, our affiliates, our employees, our users, our clients, and others.
• Complying with any court order, law, or legal process, and responding to lawful requests from public authorities, including to meet national security or law enforcement requirements.
• Investigating or preventing unlawful activities or misuse of the Services, and/or complying with any court order, law, or legal process, including to respond to any government or regulatory request.
• For such purposes as you may authorize or direct.
4. DISCLOSURE OF YOUR INFORMATION. We may disclose aggregated, anonymized information about our users to third parties, including our clients, without restriction. We may disclose information (personal or otherwise) collected about you:
• To our clients.
• To our affiliates.
• To our contractors, service providers, and other third parties we use to support our business.
• To comply with any court order, law, or legal process, and respond to lawful requests from public authorities, including to meet national security or law enforcement requirements.
• To investigate or prevent unlawful activities or misuse of the Services.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
• To a buyer or other successor or organization in the event of an actual or potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, including as part of bankruptcy, liquidation, or similar proceeding.
• With such other parties, or for such other purposes, as you may authorize or direct.
5. CHOICES AND ACCESS. We strive to provide you with choices regarding your personal information. We have created the following mechanisms to provide you with control over your information:
• Email. We include instructions in our marketing emails describing how you can opt out of future marketing or promotional emails.
You may contact us using the information in the Contact Information section to change or correct, if appropriate, Personal Information about you that we maintain.
Some Internet browsers have a “do-not-track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our Services are not set up to respond to do-not-track signals. We may permit third parties to use the Services to collect personal information about users’ online activities over time and across different websites.
We collect information under the direction of, and receive information from, our clients and may have no direct relationship with the individuals whose personal data we process under these circumstances. If you are a customer, employee, or student of one of our clients and would like to make an inquiry or complaint, please contact the client that you interact with directly.
6. DATA SECURITY. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include storing personal information you provide to us on secure cloud servers.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas, such as message boards.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information collected, received, or transmitted in connection with our Services. We are not responsible for circumvention of any privacy settings or security measures we provide.
7. DATA RETENTION. We store personal information for as long as we reasonably need it to fulfill the purposes for which it was collected. We will also retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. INTERNATIONAL DATA TRANSFERS AND PRIVACY SHIELD PARTICIPATION. We may transfer your personal information to the United States and other countries that may not have the same data protection laws as the country in which you reside. Some of these jurisdictions may not have been deemed adequate by the European Commission to provide a comparable level of protection to that of the European Economic Area (“EEA”) or Switzerland. We participate in and have certified to the U.S. Department of Commerce that we comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, the “Privacy Shield Framework”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. We are committed to subjecting to the Principles of the Privacy Shield Framework all personal information received from EEA member countries and Switzerland in reliance on the Privacy Shield Framework. If there is any conflict between this Policy and the Privacy Shield Framework Principles, the Privacy Shield Framework Principles will govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
With respect to personal information that we receive pursuant to the Privacy Shield Framework, we will remain liable for processing of that information by our agents, unless we establish that we are not responsible for the event giving rise to the damage. The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield Framework.
9. INQUIRIES AND COMPLAINTS PROCESS FOR PRIVACY SHIELD DATA AND DATA PROCESSED IN THE EEA OR SWITZERLAND. If you reside in an EEA member state or Switzerland, and your personal information is transferred to the U.S. pursuant to the Privacy Shield: In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EEA and Swiss individuals desiring to request access to their personal information or with other inquiries or complaints regarding our Policy or practices should first contact us as described in the Contact Information section of this Policy. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact the American Arbitration Association, our U.S.-based third-party dispute resolution provider, (free of charge) through the following web site: http://go.adr.org/privacyshield.html. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Under the Privacy Shield Framework, we are responsible for the processing of personal information we receive and subsequently transfer to a third-party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EEA and Switzerland, including the onward transfer liability provisions.
If you are located in the EEA or Switzerland, and we process your information in an EEA member state or Switzerland: you may have additional rights to request access to, correction of, erasure of, or the transfer of your personal information, as well as the right to object to or restrict the processing of your personal information. You may exercise these rights, if applicable, by contacting us as described in the Contact Information section of this Policy. Individuals located in the EEA or Switzerland also have the right to lodge a complaint with an EEA or Swiss supervisory authority, as applicable.
Where we are processing personal information received from or collected on behalf of our clients: We collect information under the direction of, and receive information from, our clients and may have no direct relationship with the individuals whose personal information we process under these circumstances. If you are a customer, employee, or student of one of our clients and would like to make an inquiry or complaint, please contact the client that you interact with directly.
10. ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA AND YOUR CALIFORNIA PRIVACY RIGHTS.
This section of the Policy applies only to residents of the State of California (for the purposes of this section 10 of the Policy, “consumers” or “you”), and generally describes how we collect, use, and disclose the personal information of consumers or consumer households (“California Personal Information”). However, California Personal Information does not include, and this section of the Policy does not apply to:
· Personal information excluded from the California Consumer Privacy Act (“CCPA”).
· Personal information, emergency contact information, and benefits administration information we collect about a consumer in the course of that consumer acting as our job applicant, our employee, our owner, our director, our officer, our medical staff member, or our contractor to the extent we use that information within the context of that consumer’s role as our job applicant, employee, owner, director, officer, medical staff member, or contractor.
· Personal information reflecting a communication or a transaction between us and a consumer’s organization that relates to obtaining products and services from us.
This section of the Policy applies only to the extent we direct the purposes and means of processing California Personal Information and otherwise qualify as a “business” under the CCPA. It does not apply to information we collect, disclose, or otherwise process as a “service provider” under the CCPA on behalf of our customers and business partners.
A. California Personal Information We Collect
We may have collected the following categories of California Personal Information in the preceding 12 months:
· Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
· Identifiers, including unique and online identifiers.
· Commercial information.
· Internet and electronic activity information.
· Professional or employment-related information.
· Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) related to a student and maintained by an educational institution or party acting on its behalf.
· Geolocation data.
· Sensory information, including visual and audio information.
· Protected classification characteristics under California or federal law, which includes age if 40 years or older, race, color, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information).
· Inferences drawn from your personal information.
B. Sources of California Personal Information We Collect
We collect California Personal Information from the sources described in the Information We Collect About You section of this Policy.
C. Purposes for Which We Use, Disclose, and Sell California Personal Information
We may use, disclose, and sell the categories of California Personal Information described in the California Personal Information We Collect section above for one or more of the business and commercial purposes described in the How We Use Your Information section above. We may disclose this information to the categories of third parties identified in the Disclosure of Your Information section above for the business and commercial purposes described in the How We Use Your Information section above.
D. Disclosures of California Personal Information for a Business Purpose in the Preceding 12 Months
In the preceding 12 months, we may have disclosed the categories of California Personal Information described in the California Personal Information We Collect section above to the categories of third parties identified in the Disclosure of Your Information section above for a business purpose.
E. Sales of California Personal Information
We sell California Personal Information. In the preceding 12 months we may have sold the California Personal Information categories described below:
· Identifiers, including unique and online identifiers.
· Commercial information.
· Professional or employment-related information.
· Geolocation information.
In the preceding 12 months, we sold California Personal Information to the following categories of third parties: event sponsors, advertising networks, social networks, and analytics providers.
We do not have actual knowledge that we sell California Personal Information of consumers under 16 years of age.
F. California Personal Information Rights and Choices
The CCPA and other California laws provide consumers with specific rights regarding their California Personal Information. This section describes those rights and explains how to exercise those rights.
· Opting Out of Sales of California Personal Information. You have the right to direct us to not sell your California Personal Information.
To exercise the right to opt-out, you or your authorized agent may submit a request to us by visiting the following page: Do Not Sell My Personal Information, or by calling the following toll-free number: +1 (833) 470-1234.
We may deny an opt-out request submitted by your authorized agent if the authorized agent does not submit written proof of authorization to act on your behalf.
· Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection, use, disclosure, and sale of your California Personal Information over the past 12 months. If we receive and confirm a verifiable consumer request from you pursuant to the Exercising Access, Data Portability, and Deletion Rights section below, we will disclose to you, depending on the scope of the request:
o The categories of California Personal Information we collected about you.
o The categories of sources for the California Personal Information we collected about you.
o Our business or commercial purpose for collecting California Personal Information about you.
o The categories of third parties with which we share your California Personal Information.
o The specific pieces of California Personal Information we collected about you.
o If we disclosed or sold your California Personal Information for a business purpose, a list of the categories of third parties to whom we disclosed California Personal Information for a business purpose identifying the categories of California Personal Information disclosed to those parties in the preceding 12 months and a list identifying the California Personal Information categories sold and the categories of third parties who purchased that California Personal Information.
· Deletion Request Rights. You have the right to request that we delete your California Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request pursuant to the Exercising Access, Data Portability, and Deletion Rights section below, we will delete your California Personal Information from our records, unless an exception applies.
· Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
o Calling us at +1 (833) 470-1234
o Emailing us at email@example.com
o Visiting our California Consumer Privacy Act Rights Request Form
Only you, or an agent that you provide written permission to act on your behalf, may make a verifiable consumer request related to your California Personal Information. If an authorized agent makes a request on your behalf, prior to responding we may require the authorized agent to present written and signed proof of authorization to act on your behalf, verify your identity, and confirm the authorized agent’s permission to act on your behalf directly. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must provide information sufficient to permit us to reasonably verify you are the person about whom we collected California Personal Information, or an authorized agent of that person. In order to verify your request, we may require you to provide information such as your first and last name, email address, zip code, and any other information necessary for us to verify your request. Your request also must include sufficient detail for us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with California Personal Information if we cannot verify your identity or authority to make the request and confirm the California Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, if you have a password-protected account with us we consider requests made through that account sufficiently verified when the request relates to California Personal Information associated with that specific account.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable request. If we cannot fulfill, or are permitted to decline, your request then we will alert you or your authorized agent. For data portability requests, we will select a format to provide your California Personal Information that is readily usable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.
· Non-Discrimination. Subject to certain exceptions, you have the rights to not receive discriminatory treatment for exercising your access, data portability, opt-out, and deletion rights described above.
· Direct Marketing Disclosures. Consumers who have an established business relationship with us for personal, family, or household purposes may request certain information regarding our disclosure of certain personal information to third parties for those parties’ own direct marketing purposes. If you are a consumer who has such an established business relationship with us and wish to make such a request please send us your written request by mail to:
101 Huntington Ave., Suite 2200
Boston, MA 02199
Attention: Chief Compliance Officer.
Right to Request Removal for Consumers Under the Age of 18.Consumers under the age of 18 who are registered users of the Website Services may request and obtain removal of content or information they post on the Website Services. Such request for removal does not ensure complete or comprehensive removal of the content or information posted on the Website Services. To receive instructions on how to request and obtain removal of content or information posted on the Website Services, please contact us as described below in the Contact Information section.
11. CHANGES TO OUR POLICY. It is our practice to post any changes we make to our Policy on this page. The date this Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this Policy to check for any changes.
12. CHILDREN. Our Services are not intended for children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If you are a resident of California, under the age of 18, and a registered user of the Website Services, you may refer to the Your California Privacy Rights section above for additional information.
13. EXTERNAL WEBSITES AND SERVICES. Some hyperlinks and banners contained in our Services may link to third-party websites or services. We do not operate these third-party websites or services and they are not subject to this Policy. For information on how your Personal Information will be collected, used, and disclosed, check the privacy policies of these third-party websites or services.
14. CONTACT INFORMATION. To ask questions or comment about this Policy and our privacy practices, contact us at firstname.lastname@example.org, by phone at (617) 492-9099, or
101 Huntington Ave., Suite 2200
Boston, MA 02199
Attention: Chief Compliance Officer
Additionally, EEA residents may contact our data protection officer with any questions or concerns regarding how we process their personal information at: email@example.com.