Effective Date: January 1, 2023
IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE THE BOTTOM OF THIS POLICY FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.
Personal Information We Collect
"Personal Information" is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Please see the information below for more details about the categories of Personal Information we collect. Personal Information does not include some information that is publicly available.
The table below lists categories of Personal Information we collect and a description of the types of data collected in each category:
|Personal Information Category||Data Element Collected|
|Identifiers||Your name, alias, unique personal device identifier, online identifier like a cookie ID, internet protocol address, browser type, your internet service provider, operating system, data and time you visit the Site, email address, month, day and year of your birth.|
|Commercial Information||Services purchased, obtained, or considered, content of texts or emails you send to us, pages you click-on on the Site, the amount of time spent on the Site, or other purchasing or consuming histories or tendencies.|
|Biometric Information||Key stroke activity.|
|Internet Activity||Internet or other electronic network activity information, including, but not limited to, the websites you visit before or after you visit the Site, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.|
|Geolocation Data||Imprecise location information, like the city, state and ZIP code associated with your IP address.|
|Audio Recordings||Recordings of customer service calls or security video footage.|
|Inferences drawn from other personal information||Inferences drawn from any of the information identified in this subdivision to create a profile about you that reflects your preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Sources of the Information We Collect and Purpose for Which We Collect it
The information we collect from you varies, depending on the way you use our Site or interact with our Operations. We collect information from or about you in the ways described below.
Information You Provide Directly to Us and Information We Collect Automatically When You Use Our Site
|Category of Personal Information||Purpose of Collection and Use||Examples/ Explanations|
||To Communicate With You||
||To Improve Our Site and Services||
||Advertising, Marketing, and Promotions||
||Legal Purposes and Protection of Rights||
||Deliver our Site and Services||
Information We Collect from Third Party Sources
We obtain data from various third-party companies and public sources. We may combine that data with Personal Information or other data we collect. This enhances our existing data about our customers (like adding address information), improves our ability to contact you, and enhances our marketing capabilities.
|Category||Purpose of Collection and Use||Source|
||Facilitating Purchases||Payment Processors|
Information We Collect as a Service Provider
The information we collect when providing the consulting, compliance, management and other services J. J. Keller provides, including, without limitation, those that are provided through or accessible from our Sites (collectively, our "Services") to our customers is not covered under this Policy because we don’t control what Personal Information our customers may collect using our services and how they will use it. Rather, our customers determine and control what information we collect and then we collect and process that information on their behalf. For this reason, any information collected through our Services in this manner is covered by our customers’ privacy policies.
How Long We Keep Your Personal Information
We retain Personal Information only as long as we have a legitimate business purpose to keep it. These purposes may include retaining Personal Information in order to:
- complete the transaction for which the Personal Information was collected;
- fulfill the terms of a written warranty or product recall;
- continue our ongoing business relationship with you;
- ensure the security and integrity of our Sites, services, and Operations; and
- satisfy any legal, regulatory, tax, accounting or reporting requirements.
To determine the appropriate retention period for individual categories of Personal Information we collect, we consider the nature and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure of the Personal Information; the purposes for which we process that Personal Information and whether we can fulfill those purposes through other means; and applicable legal, regulatory, tax, accounting, reporting or other requirements.
Disclosing Personal Information
We may disclose the information we collect about you in the following situations:
|Category of Information||With Whom We Disclose Personal Information||Purpose|
||Employees, Affiliates, Dealers and Distributors||We may disclose your Personal Information to our employees, affiliates, subsidiaries, dealers and distributors who have a need to know the information for our business purposes, including to facilitate a purchase and to provide service for the products you purchase.|
||Government Officials and Law Enforcement||
||Professional Advisors||Receive advice from our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to us.|
||Parties to Business Transactions||If we are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company, or if we undergo liquidation or bankruptcy proceedings, we may disclose your information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed.|
Use and Disclosure of Aggregated, De-identified Information
We may also disclose aggregated, de-identified information to third parties—such as advertisers. We do not limit our third-party providers from using, selling, licensing, distributing, or disclosing aggregated or de-identified data or using such data for their own or someone else's marketing purposes.
Cookies and Other Tracking Technologies
- Remember your preferences and allow you to enter your user name less frequently;
- Uniquely identify each user session when you access the Site
- Compile aggregated statistics to analyze our Operations;
- Present you with information targeted to your interests, including our content presented on another website and across devices;
- Present you with the opportunity to participate in a survey based on your interests in our Operations and activities on the Site; and
- Measure the effectiveness of our Operations, content, communications and advertising, including by placing web beacons (sometimes called single-pixel gifs) which show us the emails and links that have been opened by recipients. The Options/Settings section of most internet browsers will allow you to disable cookies on your browser (see below) but doing so may prevent you from using the full features of the Site. You can learn more about cookies, including how to see what cookies have been uploaded to your device and how to manage and delete them, by visiting https://www.allaboutcookies.org/. For information about your choices regarding these technologies please see "Your Access and Choices regarding your Personal Information" below.
Interest-Based Advertising and Marketing
Some companies may use information collected on our Site to deliver advertisements on our behalf or on behalf of other companies, targeted to your interests and preferences, on our Site or on other websites or applications you may visit, on your various devices, or on your social media feed and to gauge their effectiveness.
You can learn which third parties have placed cookies on your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative's website at https://optout.networkadvertising.org; or the Digital Advertising Alliance's website at https://optout.aboutads.info. For more information on mobile specific opt-out choices, please visit https://www.networkadvertising.org/mobile-choices from your mobile device.
On your mobile device you may have features that allow you to opt out of some targeted advertising ("Limit Ad Tracking" (on iOS devices) or "Opt out of Interest-Based Ads" (on Android)). To learn more about how these opt-out features work, please review your device settings.
Even if you disable tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed and that you may still receive advertising from third parties, though such advertising may not be based on your interests and preferences.
How We Use Criteo
How We Use Microsoft Ads
Accounts and other choices
Access and Updates to your Information. You can access and update most of your account information on our Site by clicking on "My Account". If you need to access, update, or delete other personal information that we may have, you can send a request to email@example.com or call us at 877-564-2333 to speak with a Customer Service Representative. To protect your privacy, before we give you access to or let you update your information, we may ask you to verify your identity or provide additional information. We will try to update and allow you to access your information for free, but if it would require a disproportionate effort on our part, we may charge a fee. We will disclose the fee before we comply with your request. We may reject a request for a number of reasons, including, for example, that the request risks the privacy of other users, requires technical efforts that are disproportionate to the request, is repetitive, or is unlawful.
Links To Other Web Sites and Services
We are not responsible for the practices employed by websites or services linked to our Site, including the information or content contained in such websites or services. This policy does not apply to those websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our Site, are subject to that third party's own rules and privacy policies. Please read the terms of such websites carefully and exercise care when providing your personally identifiable information.
We take reasonable precautions to protect your information. Please keep in mind that the Internet is not a 100% secure medium for communication, and we cannot guarantee that the information collected about you will always remain private when using our Site and services. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.
If you have any questions about this policy or the services, please contact us at: Email: Compliance@jjkeller.com; Phone: 1-833-933-0970.
Terms Applicable to California Residents Only
The California Consumer Privacy Act of 2018 and subsequent California Privacy Rights Act (together referred to herein as the “CCPA”) provide additional rights to California residents.
In the last 12 months we have not Sold your Personal Information to a third party for monetary compensation.
We may share the following categories of Personal Information with third parties that provide us with targeted advertising or data analytics services.
- Commercial Information
- Internet Activity
You have the right to opt-out of the sale or sharing of your Personal Information as described below.
We Do Not Use or Disclose Sensitive Information
We do not use or disclose sensitive information, as defined in the CPRA.
Your Rights and Choices
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know.
have a right to request that we disclose certain information about you and our collection of your Personal Information over the last 12 months. Once we receive your request and confirm your identity, we will disclose to you:
- The categories of Personal Information we collected about you;
- The categories of sources for the Personal Information we collected about you;
- Our business or commercial purpose for collecting that Personal Information;
- The categories of third parties with whom we share that Personal Information; and
- The specific pieces of Personal Information we collected about you.
Right to Delete
Except in certain cases where the CCPA does not require us to do so or provides an exception, you have the right to request that J. J. Keller delete any of your Personal Information that we collected from you and retain. Once we receive and verify your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies or the CCPA does not require us to do so.
Exceptions: In accordance with the CCPA, we may deny your deletion request under certain circumstances, which may include, but are not limited to, circumstances where retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Correct
You have the right to request that we correct inaccurate Personal Information that we collect about you. If we receive a verifiable request, we will consider it, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. We may deny your request if we are unable to verify your identity, if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances. We may request that you provide us with documentation that is relevant to your request.
Please note, we may choose to delete the contested Personal Information as an alternative to correcting it if doing so would not negatively impact you or you consent to our deletion.
Exercising Your Rights
To exercise your rights described above, please submit a verifiable consumer request to us by: calling us at 1-833-933-0970, emailing Compliance@jjkeller.com, or mailing an inquiry to: J. J. Keller & Associates, Inc. Attn: Privacy Team, 3003 Breezewood Lane, Neenah, WI 54956.>
Who Can Make a Request
If you are a California resident, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a request on behalf of your minor child. You may only make such a request twice within a 12-month period.
You have a right to submit requests to exercise your rights under the CCPA through an agent. We may deny a request from an agent if we do not have proof that they are authorized by you to act on your behalf.
Verifying Your Request
In order to process your request, you must provide:
- Information sufficient to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- A request with sufficient detail to allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (an additional 45 days up to a total of 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. If applicable, the response we provide will also explain the reasons we cannot comply with a request.
If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You have a right to not receive discriminatory treatment for exercising any of your rights under the CCPA.
Honoring Opt-Out Signals
We process opt-out preference signals (“Signals”) when you visit our Site. This means that you can opt-out of us sharing your Personal Information without having to contact us or otherwise submit a request to us. For us to process your opt-out, you must have a valid Signal in a format commonly used and recognized by us such as an HTTP header field.
If we receive or detect a Signal, we will treat the Signal as a valid request to opt-out of the sale or sharing of your Personal Information for that browser or device, and, if known, for you.
To set up a Signal, you can visit https://globalprivacycontrol.org/.
California Shine the Light
If you have any questions or comments about this notice, the ways in which J. J. Keller collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
J. J. Keller & Associates, Inc.
ATTN: Privacy Team
3003 Breezewood Lane
Neenah, WI 54956