Effective on November 7, 2018
For our purposes, “Consumer” refers to an individual who visits and interacts with a third party website or application, such as a website operated by a Publisher (as further defined below) on which the individual indicated an interest in a particular product or service and provided contact information in response to a form or questionnaire, as well as browsed or otherwise interacted within such sites.
WHAT WE DO
OUR RELATIONSHIP TO CONSUMERS
We have three types of Clients who access, use and interact with our Platform in different ways, 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) (“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.
“Partners” are companies who work with Jornaya to provide supplemental services to Publishers or Queriers through our Services, either by incorporating certain aspects of our Services, or by integrating with our Services. Partners may contribute their own data or access data via APIs, SDKs, web related services. In some cases, we may use Partner pixels, cookies, scripts or tags alongside our Script.
HOW WE COLLECT, STORE AND USE CLIENT DATA
If you enter information into an open text field 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 PII that you volunteered. The only information our Clients may learn from utilizing our Services is anonymous, non-personally identifiable information (“Non-PII”).
Examples of Non-PII which may be collected include:
- Device and browser information: This is technical information about the device or browser you use on the Publisher website. This information is found in every communication sent over the Internet such as Internet Protocol (IP) Address, browser type, browser language and operating system.
- Browsing activity: This is information regarding your browsing activity on a Publisher Platform. This information is similar to the information a Publisher may collect as part of their web analytics service (e.g. Google Analytics) or web server logs; such as what pages you visited and when, which parts of the Publisher’s content you were exposed to, and how long you remained on an individual page.
COOKIES AND RELATED TECHNOLOGIES
Cookies are small data files that are served by our platform and stored on your device. They enable your device to be identified when you move between different websites and applications. Our Clients may choose to use this information as part of our Services. We may also drop cookies from our Clients for the purposes described above. You can choose to configure your web browser to refuse any or all attempts to serve a cookie, at your discretion.
We share anonymous, Non-PII only as necessary to enable us to provide our Services to our Clients who wish to certify that a certain event(s) took place at the Publisher Platform in which a Consumer legitimately participated. 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 utilizing certain aspects of our Services. If any Contributed Data is provided by a Client, this information is utilized solely to generate applicable Jornaya derived data (which is anonymous and does NOT expose any PII) associated with that query. We rely solely on our Clients to have secured the proper permissions from Consumers or other sources where they have been provided with the Contributed Data.
CONSUMER CHOICES AND HOW TO OPT-OUT
We recognize how important online privacy is to Consumers, and we support the following options for Consumers to control or opt out of certain collection and disclosure of information:
- Opting out of Internet-based advertising. Our Clients may use certain insights gained by the use of our Platform to tailor the advertising Consumers see on our Clients’ websites. We do not deliver advertising on our own, including targeted advertising. In order to opt-out of targeted advertising, Consumers must opt-out of Interest-based advertising either through options provided through the websites Consumers visit and interact with, or by using an industry-wide opt-out tool, such as:
Please note that Consumers will still see advertisements after opting out; these advertisements will just not be tailored to the Consumers’ interests.
- Opting out of cookies and beacons. If a Consumer does not want cookies placed on the Consumer’s device at all, the Consumer can adjust the device’s browser settings to display a notification before any cookie is placed. Browser settings may also be changed to refuse all cookies, or only third-party cookies. Likewise, the Consumer can remove any cookies that have already been placed on the device. Please note that settings may need to be adjusted on each browser and device used by the Consumer.
- Avoiding certain websites. A Consumer may avoid the collection and use of certain information by not visiting Publisher Platforms that utilize our Services. Consumers must consult the privacy policies of the websites they visit to determine whether our Scripts or Services are used on those
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
We are an independent service provider to our Clients. The fact that we provide our Platform and related services to our Clients is not meant to be an implied endorsement of, authorization of, or representation about any particular Client, nor is it an endorsement of, or representation about any Client’s privacy or information security policies or practices. When we choose to work with a Client, we do not intend by such collaboration to make any implied representation about our Clients generally or our Clients’ products and services. This Services Policy applies only to our Platform. Our Clients’ websites and services are provided subject to separate terms and conditions and separate policies, including separate privacy policies regarding the use and disclosure of Consumer PII. Our Clients are responsible for instructing Consumers to read all applicable terms and conditions, policies or statements of the websites they visit, especially those websites that collect Consumer PII.
Our Platform (including our Services) are intended for use solely within the United States of America and is directed to Clients solely 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.
QUESTIONS OR COMMENTS