Privacy Policy

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Privacy Policy of JAOPartners.com

Last updated: September 12, 2021

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means      a unique account created for You to access our Service or parts of our      Service.
• Business,      for the purpose of the CCPA (California Consumer Privacy Act), refers to      the Company as the legal entity that collects Consumers' personal      information and determines the purposes and means of the processing of      Consumers' personal information, or on behalf of which such information is      collected and that alone, or jointly with others, determines the purposes      and means of the processing of consumers' personal information, that does      business in the State of California.
• Company (referred      to as either "the Company", "We", "Us" or      "Our" in this Agreement) refers to JAOPartners.com website.

For the purpose of the GDPR, the Company is the Data Controller.

• Consumer,      for the purpose of the CCPA (California Consumer Privacy Act), means a      natural person who is a California resident. A resident, as defined in the      law, includes (1) every individual who is in the USA for other than a      temporary or transitory purpose, and (2) every individual who is domiciled      in the USA who is outside the USA for a temporary or transitory purpose.
• Country refers      to: United States
• Cookies are      small files that are placed on Your computer, mobile device or any other      device by a website, containing the details of Your browsing history on      that website among its many uses.
• Data      Controller, for the purposes of the GDPR (General Data Protection      Regulation), refers to the Company as the legal person which alone or      jointly with others determines the purposes and means of the processing of      Personal Data.
• Device means      any device that can access the Service such as a computer, a cellphone or      a digital tablet.
• Do      Not Track (DNT) is a concept that has been promoted by US      regulatory authorities, in particular the U.S. Federal Trade Commission      (FTC), for the Internet industry to develop and implement a mechanism for      allowing internet users to control the tracking of their online activities      across websites.
• Personal      Data is any information that relates to an identified or      identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

• Sale,      for the purpose of the CCPA (California Consumer Privacy Act), means      selling, renting, releasing, disclosing, disseminating, making available,      transferring, or otherwise communicating orally, in writing, or by      electronic or other means, a Consumer's personal information to another      business or a third party for monetary or other valuable consideration.
• Service refers      to the Website.
• Service      Provider means any natural or legal person who processes the data      on behalf of the Company. It refers to third-party companies or      individuals employed by the Company to facilitate the Service, to provide      the Service on behalf of the Company, to perform services related to the      Service or to assist the Company in analyzing how the Service is used. For      the purpose of the GDPR, Service Providers are considered Data Processors.
• Usage      Data refers to data collected automatically, either generated by      the use of the Service or from the Service infrastructure itself (for      example, the duration of a page visit).
• Website refers      to JAOPartners.com, accessible from https://www.JAOPartners.com
• You means      the individual accessing or using the Service, or the company, or other      legal entity on behalf of which such individual is accessing or using the      Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email      address
• First      name and last name
• Phone      number
• Address,      State, Province, ZIP/Postal code, City
• Usage      Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies      or Browser Cookies. A cookie is a small file placed on Your      Device. You can instruct Your browser to refuse all Cookies or to indicate      when a Cookie is being sent. However, if You do not accept Cookies, You      may not be able to use some parts of our Service. Unless you have adjusted      Your browser setting so that it will refuse Cookies, our Service may use      Cookies.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary      / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Cookies      Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality      Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking      and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To      provide and maintain our Service, including to monitor the usage of      our Service.
• To      manage Your Account: to manage Your registration as a user of the      Service. The Personal Data You provide can give You access to different      functionalities of the Service that are available to You as a registered      user.
• For      the performance of a contract: the development, compliance and      undertaking of the purchase contract for the products, items or services      You have purchased or of any other contract with Us through the Service.
• To      contact You: To contact You by email, telephone calls, SMS, or      other equivalent forms of electronic communication, such as a mobile      application's push notifications regarding updates or informative      communications related to the functionalities, products or contracted      services, including the security updates, when necessary or reasonable for      their implementation.
• To      manage Your requests: To attend and manage Your requests to Us.
• and      improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• None

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply      with a legal obligation
• Protect      and defend the rights or property of the Company
• Prevent      or investigate possible wrongdoing in connection with the Service
• Protect      the personal safety of Users of the Service or the public
• Protect      against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

• Google      Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You      have given Your consent for processing Personal Data for one or more      specific purposes.
• Performance      of a contract: Provision of Personal Data is necessary for the      performance of an agreement with You and/or for any pre-contractual      obligations thereof.
• Legal      obligations: Processing Personal Data is necessary for compliance      with a legal obligation to which the Company is subject.
• Vital      interests: Processing Personal Data is necessary in order to      protect Your vital interests or of another natural person.
• Public      interests: Processing Personal Data is related to a task that is      carried out in the public interest or in the exercise of official      authority vested in the Company.
• Legitimate      interests: Processing Personal Data is necessary for the purposes      of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request      access to Your Personal Data. The right to access, update or      delete the information We have on You. Whenever made possible, you can      access, update or request deletion of Your Personal Data directly within      Your account settings section. If you are unable to perform these actions      yourself, please contact Us to assist You. This also enables You to      receive a copy of the Personal Data We hold about You.
• Request      correction of the Personal Data that We hold about You. You have      the right to have any incomplete or inaccurate information We hold about      You corrected.
• Object      to processing of Your Personal Data. This right exists where We      are relying on a legitimate interest as the legal basis for Our processing      and there is something about Your particular situation, which makes You      want to object to our processing of Your Personal Data on this ground. You      also have the right to object where We are processing Your Personal Data      for direct marketing purposes.
• Request      erasure of Your Personal Data. You have the right to ask Us to      delete or remove Personal Data when there is no good reason for Us to      continue processing it.
• Request      the transfer of Your Personal Data. We will provide to You, or to      a third-party You have chosen, Your Personal Data in a structured,      commonly used, machine-readable format. Please note that this right only      applies to automated information which You initially provided consent for      Us to use or where We used the information to perform a contract with You.
• Withdraw      Your consent. You have the right to withdraw Your consent on      using your Personal Data. If You withdraw Your consent, We may not be able      to provide You with access to certain specific functionalities of the      Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

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CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

• Category      A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

• Category      B: Personal information categories listed in the California Customer      Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A 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. Some personal information included in this category may overlap with other categories.

Collected: No.

• Category      C: Protected classification characteristics under California or federal      law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

• Category      D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

• Category      E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

• Category      F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

• Category      G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

• Category      H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

• Category      I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

• Category      J: Non-public education information (per the Family Educational Rights and      Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

• Category      K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

• Publicly      available information from government records
• Deidentified      or aggregated consumer information
• Information      excluded from the CCPA's scope, such as:
  • Health       or medical information covered by the Health Insurance Portability and       Accountability Act of 1996 (HIPAA) and the California Confidentiality of       Medical Information Act (CMIA) or clinical trial data
  • Personal       Information covered by certain sector-specific privacy laws, including       the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA)       or California Financial Information Privacy Act (FIPA), and the Driver's       Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly      from You. For example, from the forms You complete on our Service,      preferences You express or provide through our Service, or from Your      purchases on our Service.
• Indirectly      from You. For example, from observing Your activity on our Service.
• Automatically      from You. For example, through cookies We or our Service Providers set      on Your Device as You navigate through our Service.
• From      Service Providers. For example, third-party vendors to monitor and      analyze the use of our Service, third-party vendors for payment      processing, or other third-party vendors that We use to provide the      Service to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

• To      operate our Service and provide You with our Service.
• To      provide You with support and to respond to Your inquiries, including to      investigate and address Your concerns and monitor and improve our Service.
• To      fulfill or meet the reason You provided the information. For example, if      You share Your contact information to ask a question about our Service, We      will use that personal information to respond to Your inquiry. If You      provide Your personal information to purchase a product or service, We      will use that information to process Your payment and facilitate delivery.
• To      respond to law enforcement requests and as required by applicable law,      court order, or governmental regulations.
• As      described to You when collecting Your personal information or as otherwise      set forth in the CCPA.
• For      internal administrative and auditing purposes.
• To      detect security incidents and protect against malicious, deceptive,      fraudulent or illegal activity, including, when necessary, to prosecute      those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

• Category      A: Identifiers
• Category      B: Personal information categories listed in the California Customer      Records statute (Cal. Civ. Code § 1798.80(e))
• Category      D: Commercial information
• Category      F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Share of Personal Information

We do NOT share Your personal information 

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

• By      visiting this page on our website: https://www.JAOPartners.com/contact/

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide      sufficient information that allows Us to reasonably verify You are the      person about whom We collected personal information or an authorized      representative
• Describe      Your request with sufficient detail that allows Us to properly understand,      evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

• Verify      Your identity or authority to make the request
• And      confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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