Generally, our Clients are as follows:
“Publishers” are companies who are accessing and using the Services to create Universal LeadiDs (as further defined below) on their own web site(s) or platform(s) (e.g., Publisher Platforms).
“Queriers” are companies who generate data on their own or receive data from another party with a Universal LeadiD or other identifiers (“Identifiers”) and desire to verify and/or append certain attributes to the Identifiers by querying our network. A Querier can also be a Publisher.
ACCOUNT SET UP
Information collection. When you, as a Client, set up an account to access and use the Site, you voluntarily enter information that may be used to identify or locate you, such as your full name, postal address, e-mail address, phone number, website username, social media platform ID (e.g. Facebook ID, Twitter ID), or billing information, as well as other non-public information that is associated with this information (“Client Personally Identifiable Information” or “Client PII”). We will collect Client PII only when you knowingly provide it, including when you register for the Site, provide feedback, or request information. We use your Client PII to administer your account, to provide you with appropriate access to and use of the Platform, to send communications and administrative emails, to respond to your inquiries, and to send marketing and product update messages to those who ask for such messages. Typically, individuals acting on behalf of a Client would provide this type of information on the Site when registering for an account to get access to our Platform (for example, a Publisher contact may provide an email address when registering on the Site and creating a username and password).
Information sharing. We do not share Client PII with third parties for their commercial use. When you use certain Services, your Client PII captured through the Site may be shared, since some of the requested information may include Client PII that is associated with the information within your account, such as your company's name.
Controlling Client PII. If you have provided Client PII, such as your email address when registering for access to our Site, you may modify that information at any time by visiting your account settings on our Site. You can opt-out of receiving certain email communications from the Site by clicking the “Unsubscribe” link at the bottom of each email or through a similar opt-out link that may be provided, except for communications required to process your transactions and provide you with the requested Services. You may also contact us to have your account disabled.
USING OUR SERVICES ON PUBLISHER PLATFORMS
The information associated with a Universal LeadiD is anonymous and subject to confidentiality obligations at all times. If a Consumer enters information into open text fields within a form on a Publisher Platform, our Services consider this information as potential personally identifiable information (“PII”) and automatically encrypts that information using a cryptographic hash function which makes it infeasible for anyone, including us, to store, retrieve, reverse-engineer, or utilize the actual PII that was volunteered by the Consumer. The only information from a Consumer that an applicable Client may directly gain from utilizing our Services is anonymous, non-personally identifiable information (“Non-PII”). In addition, the provision of our Services may facilitate the capture of other Non-PII through the Publisher Platform at the time a Consumer visits a Publisher Platform, including the Consumer’s Internet Protocol (IP) address, browser type, browser language and the date and time that web page was visited, as well as other Non-PII.
Information sharing. We share anonymous, Non-PII only as necessary to enable us to provide our Services to Queriers who wish to verify that a certain event(s) took place at the Publisher Platform in which a Consumer legitimately participated and to ensure that the data was not tampered with as it was transmitted to other companies; and/or subsequently through the Consumer’s browser journey. At times, anonymous Non-PII is shared with Partners to enable us to provide certain Services to Publishers and/or Queriers.
A Client may provide certain additional information in its possession, such as conversion data, and consumer information and/or Identifiers (“Contributed Data”), when querying the Jornaya API, or by batch processing. If any Contributed Data is provided by the Querier as part of a query or batch data, this information is utilized solely to generate applicable Jornaya Derived Data (which is anonymous and does NOT expose any PII) associated with that query.
Controlling Consumer information. If a Consumer does not want us to store his or her information, the Consumer can opt-out by not visiting or not engaging with Publisher Platforms that utilize our Scripts or Services, or by requesting at the Publisher Platforms the Consumer visits not to capture or use certain information captured during an event on the Publisher Platforms. It is up to you as the Publisher, Querier and/or Partner as applicable to ensure that the Consumers have the necessary avenues or means to be able to opt-out of their data being shared with us or any other party with whom you choose to share it.
TO BE CLEAR, JORNAYA DOES NOT INTERACT DIRECTLY WITH CONSUMERS SINCE SUCH CONSUMERS ARE VISITING YOUR PUBLISHER PLATFORMS WHERE YOU HAVE PROVIDED PERMISSION FOR OUR SCRIPTS TO COLLECT EVENT INFORMATION.
ADDITIONAL SHARING AND DISCLOSURES
In addition to the specific disclosures of data related to our Platform described above, we may also disclose or share data collected by our Platform under the following circumstances:
- As required by appropriate third parties, including government and law enforcement authorities, if we have a good faith belief that disclosure of such data is reasonably necessary to (i) satisfy applicable law, regulation, legal process, or an enforceable governmental request; (ii) enforce our agreements with Clients, including in the course of investigation of potential breaches of such agreements; or (iii) detect, prevent, or otherwise address fraud, security, or technical issues;
- To protect against harm to the rights, property, or safety of Jornaya, our Clients, Consumers, or the public, as required or permitted by law;
- In the event we go through a business transition, such as a merger with, or acquisition by, another company; or the sale of all or a portion of our assets, we may disclose data to the party or parties involved in preparation for, and as incident to, such business transition; and
- To aggregate Non-PII data for reporting, analytics, and other business reasons, including to promote or describe the use of our Services and Platform.
INFORMATION SECURITY AND RETENTION
We use security measures to protect against unauthorized access to and unauthorized alteration, disclosure, and destruction of data collected, processed, and stored by our Platform. These security measures include firewalls; encryption; internal reviews of our data collection, storage, and processing practices; obligations of confidentiality; and restrictions on logical and physical access to data. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that information will remain secure under all circumstances. In the event we utilize third party services in the provision of the Platform, we rely on those third parties’ representations and warranties. We retain information we collect through the Platform indefinitely, or as required by applicable law.
We do not knowingly collect or maintain information from individuals who are under 13 years of age, and no part of our Platform is designed to attract people under the age of 13. Protecting the privacy of children is very important to us. If we obtain knowledge that a Client or Consumer is under the age of 13, we will take steps to remove that individual’s information from our databases.
INDEPENDENT SERVICE PROVIDER
Our Platform is intended for use solely within the United States of America and is directed to Clients located in the United States of America. We make no representation that the Platform is appropriate or available for use in locations outside the United States. Unless otherwise expressly stated, all marketing or promotional materials found on or accessible through the Platform are intended to be directed to individuals, companies, and other entities located in the United States. We reserve the right to limit, in our sole discretion, the provision of any feature, product, or service to any person or geographic area. Any offer for a feature, product, or service made on or through the Platform is void where prohibited. If you choose to access the Platform, or implement our Scripts on, or make the Services available via, a Publisher Platform, you do so on your own initiative and are solely responsible for compliance with all applicable local laws. If you access the Platform from outside the United States, you acknowledge and agree that your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your submission of such information represents your agreement to the transfer of such information to the United States and the collection, use, and disclosure of your information in accordance with United States law and our Privacy Policies.
QUESTIONS OR COMMENTS