Effective Date: January 1, 2023
J. J. Keller collects certain information about you when you interact with us through this website, irrespective of how you access it ("Website") or through our mobile applications ("App") (which we will refer to together as the "Site"). This Privacy Policy provides information about how we collect, use, share, disclose, and protect the Personal Information we gather from you and others through the Site and our business operations (the "Operations").
IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE THE BOTTOM OF THIS POLICY FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.
"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. |
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.
| Category of Personal Information | Purpose of Collection and Use | Examples/ Explanations |
|---|---|---|
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To Communicate With You |
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Business Purposes |
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To Improve Our Site and Services |
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Advertising, Marketing, and Promotions |
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Legal Purposes and Protection of Rights |
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Deliver our Site and Services |
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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 |
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Marketing |
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Business Purposes |
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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.
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:
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.
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. |
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Government Officials and Law Enforcement |
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Service Providers |
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Third-Parties |
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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. |
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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. |
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.
We use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) when you use our Site. Cookies are small data files that are uploaded to the hard drive or other storage on devices that access, use, or interact with portions of our Site. Among other things, cookies help us improve our Platform and our users’ experience. We and our research, technology, and marketing partners, affiliates, analytics, or service providers may upload unique Cookies to your device to collect information about your use of our Site and potentially other online activities you engage in over time across different platforms and other online applications to:
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.
We work with Criteo to help us deliver marketing. Criteo uses cookies and other tracking technologies to serve personalized advertising. For more information about Criteo’s privacy practices, please see their privacy policy, available at https://www.criteo.com/privacy/. To learn how to disable Criteo services on Internet browsers, please visit https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/ and on mobile devices, please visit https://www.criteo.com/privacy/disable-criteo-services-on-mobile-applications/.
We work with Microsoft to conduct ad campaigns using Microsoft Advertising. Microsoft may collect or receive personal information about you through the use of cookies in connection with our use of Microsoft Advertising. For more information about Microsoft’s privacy practices, please see the Microsoft Privacy Statement, available at https://privacy.microsoft.com/en-us/privacystatement.
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 protected] 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.
We work with Google Analytics, a web analytics service provided by Google, to help us analyze how users use our Sites. Google Analytics uses Cookies to collect information about your use of the Site. This information is then transmitted to and stored by Google on servers in the United States. If you access our Site through different devices, Google may associate your devices with one another. You can prevent Google’s collection and use of the data it collects as defined in its policy by downloading and installing this browser plug-in: https://tools.google.com/dlpage/gaoptout?hl=en-GB. For more information about Google Analytics cookies, please see Google’s help pages (https://support.google.com/analytics/answer/6004245) and privacy policy (https://www.google.com/intl/en/policies/privacy/).
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: [email protected]; Phone: 1-833-933-0970.
We may make changes to this Privacy Policy from time to time, in our sole discretion. We will provide you notice of material changes to this Policy through our Website or App. Your continued use of a Service after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully.
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.
Subject to exceptions permitted by applicable laws and verification of your identity, if you live in California, you may exercise the following rights with regard to your Personal Information. Capitalized terms in this Section that are not defined elsewhere in this Privacy Policy have the definitions set forth in the CCPA.
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.
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, as defined in the CPRA.
The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
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:
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:
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.
To exercise your rights described above, please submit a verifiable consumer request to us by: calling us at 1-833-933-0970, emailing [email protected], or mailing an inquiry to: J. J. Keller & Associates, Inc. Attn: Privacy Team, 3003 Breezewood Lane, Neenah, WI 54956.
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.
In order to process your request, you must provide:
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.
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.
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/.
Under California Civil Code Section 1798.83, California residents have the right to obtain (a) a list of all third parties to whom the Company may have disclosed your Personal Information within the past year for direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. Please contact us as set forth at the end of this Privacy Policy to receive this information.
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:
Phone: 1-833-933-0970
Email: [email protected]
Postal Address:
J. J. Keller & Associates, Inc.
ATTN: Privacy Team
3003 Breezewood Lane
Neenah, WI 54956