Effective Date: June 1, 2024

J. J. Keller Privacy Policy

J. J. Keller collects certain information about you when you interact with us through this website, irrespective of how you access it ("Website") when you interact with us through our mobile applications ("App") and when you access or use features and services available through our Website and App ("Services") (we refer to our Website, App, and Servicesin this Privacy Policy 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 "ADDITIONAL PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS" SECTION AT THE BOTTOM OF THIS PRIVACY POLICY FOR ADDITIONAL INFORMATION THAT MAY APPLY TO YOU.

What Is Personal Information?

"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 public information that is lawfully made available to the public.

Additionally, Personal Information does not include information that is deidentified or aggregated in a way that it cannot be used to identify a particular consumer or household (“Deidentified Data”). We commit to maintaining Deidentified Data in its deidentified form and not to attempt to reidentify the Deidentified Data, except and solely for the purpose of determining whether our deidentification processes satisfy the requirements of applicable laws.

Please note, this Privacy Policy does not apply to Personal Information we process on behalf of our clients in connection with the consulting, compliance, management and other services J. J. Keller provides, including, without limitation, those that are provided through or accessible from our Sites because we don’t control what Personal Information our clients may collect in connection with their use of the services we provide them or how they will use it. Rather, our clients determine and control what Personal Information we collect on their behalf and the purposes for which we process that Personal Information. For this reason, any Personal Information we collect and process on behalf of our clients in connection with the services we provide them are covered by our clients’ applicable privacy policies.

Categories of Personal Information We Collect

The categories of Personal Information we collect and use in connection with our Sites and Operations may fall into one or more of the categories described below. Please note, the types of Personal Information provided as examples for each category are not a representation that we will actually collect that specific type of Personal Information from or about you.

Personal Information Category	Examples of Possible Data Elements 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.
Customer Records	Your 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. Please note, for purposes of the California Consumer Privacy Act (“CCPA”), this category of Personal Information constitutes any information described in Cal. Civ. Code 1798.80(e).
Legally Protected Characteristics	Your race, religion, sexual orientation, gender expression, marital status, and age. Please note, for purposes of the CCPA, this category of Personal Information constitutes characteristics of protected classifications under California or federal law.
Commercial Information	Services purchased, obtained, or considered, content of mail, texts or emails where we are the intended recipient, or other purchasing or consuming histories or tendencies.
Internet or Other Electronic Network Activity Information	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, keystrokes and mouse movements, and information regarding your interaction with an internet website, application, or advertisement.
Non-Sensitive Geolocation Data	Imprecise location information, like the city, state and ZIP code associated with your IP address.
Audio and Video Recordings	Recordings of customer service calls or security video footage. Please note, for purposes of the CCPA, this category of Personal Information constitutes audio, electronic, visual, thermal, olfactory, or similar information.
Professional or Employment-Related Information	Job title, job history, or other similar information.
Inferences	Inferences drawn from any of the information identified above to create a profile about you that reflects your preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sensitive Personal Information	Social security number, account login credentials, racial or ethnic origin, religious beliefs, or contents of mail, email, or text messages where we are not the intended recipient of the communication.

Sources of the Personal Information We Collect

A large portion of the Personal Information we collect about you in connection with our Site and Operations is collected directly from you or in connection with your access to, use of, or interaction with our Site and Operations (including Personal Information we automatically collect). You have the option not to provide any Personal Information we ask you to provide in connection with your access to, use of, or interaction with our Site or Operations. However, there are some features on our Site and certain activities associated with our Operations where we have to collect certain Personal Information, and, if you do not provide us with the required Personal Information, you will not be able to access, use, or interact with that feature or engage in that activity. This is especially true where it is impossible for the feature to operate or engage in the activity without certain Personal Information. For example, it is impossible for us to allow you to login to an account on our Site if you do not provide your login credentials.

We may also collect information (which may include Personal Information) about you from third parties, including, without limitation, online and offline sources, social media platforms, advertising networks, or other public or commercial sources, which may include, without limitation, the following categories of third parties:

Third Party Category	Examples/Explanations
Social Media Platforms	This category includes social media platforms owned or operated by third parties, such as Facebook, Instagram, LinkedIn, Twitter, and YouTube, where we maintain a social media account or where you otherwise interact with us or share our content.
Transactional Third Parties	This category includes third parties who are not related to us but provide us with Personal Information necessary to enable us to provide you with certain features and functionalities of the Site or perform activities associated with our Operations.
Service Providers	This category includes third parties that provide services to us related to the functionality and operation of our Site and conducting our Operations, such as hosting, managing communications we send and receive, and processing orders and payments.
Targeted Advertising Partners	This category includes third parties that facilitate the delivery of our targeted advertisements, promotions, and offers.
Analytics Providers	This category includes third parties that operate tracking technologies, such as web beacons, cookies, clear gifs, and pixel tags on our Site to collect information used to analyze the use and performance of our Site, including, among other things, measuring the effectiveness of our Site, content, communications, and advertising. This category also includes the use of replay technologies as further described in the “How we Use Session Replay Services” section below.
Professional Advisors	This category includes third parties that provide professional advice to us about the operation of our Site and our Operations, such as our attorneys, accountants, financial advisors, and other business advisors.
Government Officials/Law Enforcement	This category includes law enforcement, government officials, and other private parties we interact with in connection with complying with legal requirements, pursuing and defending against lawsuits, protecting our or a third party’s property and rights, protecting the security and integrity of our Site, and preventing or stopping illegal, unethical, fraudulent, and abusive activities.
Other Users	This category includes other users of our Site or third parties we interact with in connection with our Operations, such as our clients and others that refer you to us or take actions on or through our Site on your behalf.

Our Purposes for Collecting and Using Personal Information

The following table describes the purposes for which we may collect Personal Information about you in connection with our Site and Operations, along with the categories of Personal Information we collect for those purposes, and who we collect or receive that Personal Information from.

Purpose of Collection and Use	Examples/Explanations	Category of Personal Information	Sources of Personal Information
To Communicate With You	Responding to your customer service requests or any other inquiry or correspondence you send to us, as well as responding to you using our Live Chat feature; Providing you with updates, reminders, or other informational or educational content; Presenting you with the opportunity to participate in surveys, and recording your responses; Responding to your request to exercise your California privacy rights; Notifying you of changes to our Terms or this Privacy Policy; and As you request or consent to.	Personal Information Categories Identifiers Customer Records Commercial Information Internet or Other Electronic Network Activity Audio and Video Recordings Professional or Employment-Related Information Sensitive Personal Information Account Log-In Credentials	You Third Party Sources Social Media Platforms Transactional Third Parties Service Providers Analytics Providers Other Users
Operating our Site	Creating and servicing accounts; Facilitating, processing, and fulfilling orders and transactions; Verifying customer information; Processing payments; Ensuring the security and integrity of our Site; Identifying and repairing errors that prevent any portion of our Site from operating as intended; Providing access to our Site; and Conducting other internal business operations permitted under applicable law	Personal Information Categories Identifiers Customer Records Legally Protected Characteristics Commercial Information Internet or Other Electronic Network Activity Information Non-Sensitive Geolocation Data Audio and Video Recordings Professional or Employment-Related Information Sensitive Personal Information Account Log-In Credentials	You Third Party Sources Social Media Platforms Transactional Third Parties Service Providers Analytics Providers Other Users
Improving Our Site	Evaluating frequently asked questions, contacting you about Site and service usage and assisting you in better using our Site and services; Contacting you about usage of our Site; Assisting you in better accessing, using, and interacting with our Site; Troubleshooting errors on our site; Generating statistics about access to, use of, or interaction with our Site, including identifying geographic regions where our users are located; Analyzing and developing the products and services we provide; Monitoring and reviewing trends and usage related to our Site; Benchmarking our Site against similar offerings from other companies; Developing a better understanding how our users access, use, and interact with our Site, including monitoring, evaluating, and analyzing how users access, use, and interact with our Site and determining which features and portions of our Site are the most popular.	Personal Information Categories Identifiers Customer Records Commercial Information Internet or Other Electronic Network Activity Information Non-Sensitive Geolocation Data Audio and Video Recordings Inferences	You Third Party Sources Social Media Platforms Transactional Third Parties Service Providers Analytics Providers
Advertising, Marketing, and Promotions	Sending you promotions; Serving you targeted advertising; Notifying you of new services, products or programs; Enabling you to participate in contests, sweepstakes, or promotions; and Presenting you with marketing related to our Operations, including promotions, coupons, other discount offers, and more relevant display advertisements.	Personal Information Categories Identifiers Customer Records Commercial Information Internet or Other Electronic Network Activity Information Non-Sensitive Geolocation Data Inferences	You Third Party Sources Social Media Platforms Service Providers Targeted Advertising Partners Analytics Providers
Legal Purposes and Protection of Rights	Preventing, detecting, investigating, or remediating security or other legal concerns, including fraud; Protecting the rights, property, or safety of J. J. Keller, our users, or any other person, including any copyright-protected content on the Site; Complying with applicable laws, regulations, or industry requirements; Responding to law enforcement or government requests and as required by applicable law, court orders, or governmental regulations; and Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of J. J. Keller's assets, whether as an on-going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the J. J. Keller assets transferred include information held by J. J. Keller about our customers.	Personal Information Categories Identifiers Customer Records Legally Protected Characteristics Commercial Information Internet or Other Electronic Network Activity Information Non-Sensitive Geolocation Data Audio and Video Recordings Professional or Employment-Related Information Sensitive Personal Information Account Log-in credentials	You Third Party Sources Social Media Platforms Transactional Third Parties Service Providers Analytics Providers Professional Advisors Government Officials/Law Enforcement Other Users

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

In order to operate our Site and carry out other activities permitted by applicable laws, we may disclose certain Personal Information we have collected or received to certain categories of third parties. The following table identifies the categories of Personal Information we may disclose to each type of third party and the purpose for those disclosures. Please note, these disclosures are in addition to any disclosures to third parties you authorize or instruct us to make.

Third Party Category	Purpose for Disclosure	Categories of Personal Information Disclosed
Social Media Platforms	provide targeted advertising or other marketing services perform data analysis and statistical analysis	Personal Information Categories Identifiers Commercial Information Internet or Other Electronic Network Activity Non-Sensitive Geolocation Information Professional or Employment-Related Information Inferences
Service Providers	process and fulfill your orders provide payment processing services operate and manage our Site and to improve the content and functionality of our Site help us collect and analyze Personal Information for lawful business purposes, including providing data processing services provide non-targeted advertising and other marketing, including helping to conduct promotions and provide public relations services perform data analysis and statistical analysis as otherwise indicated at the time and point of collection (or as was obvious at the time and point of collection)	Personal Information Categories Identifiers Customer Records Legally Protected Characteristics Commercial Information Internet or Other Electronic Network Activity Non-Sensitive Geolocation Information Audio and Video Recordings Professional or Employment-Related Information Sensitive Personal Information Categories Account Log-In Credentials
Service Providers	process and fulfill your orders provide payment processing services operate and manage our Site and to improve the content and functionality of our Site help us collect and analyze Personal Information for lawful business purposes, including providing data processing services provide non-targeted advertising and other marketing, including helping to conduct promotions and provide public relations services perform data analysis and statistical analysis as otherwise indicated at the time and point of collection (or as was obvious at the time and point of collection)	Personal Information Categories Identifiers Customer Records Legally Protected Characteristics Commercial Information Internet or Other Electronic Network Activity Non-Sensitive Geolocation Information Audio and Video Recordings Professional or Employment-Related Information Sensitive Personal Information Categories Account Log-In Credentials
Transactional Third Parties	engage in an anticipated or actual merger or acquisition, bankruptcy or other sale of all or a portion of our assets	Personal Information Categories Identifiers Customer Records Legally Protected Characteristics Commercial Information Internet or Other Electronic Network Activity Non-Sensitive Geolocation Information Professional or Employment-Related Information Inferences Sensitive Personal Information Categories Account Log-In Credentials
Targeted Advertising Parties	provide targeted advertising or other marketing services provide data analysis and statistical analysis	Personal Information Categories Identifiers Commercial Information Internet or Other Electronic Network Activity Non-Sensitive Geolocation Information Inferences Sensitive Personal Information Categories Account Log-In Credentials
Analytics Providers	provide targeted advertising or other marketing services provide data analysis and statistical analysis	Personal Information Categories Identifiers Commercial Information Internet or Other Electronic Network Activity Inferences Sensitive Personal Information Categories Account Log-In Credentials
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	Personal Information Categories Identifiers Customer Records Legally Protected Characteristics Commercial Information Internet or Other Electronic Network Activity Non-Sensitive Geolocation Information Audio and Video Recordings Professional or Employment-Related Information Inferences Sensitive Personal Information Categories Account Log-In Credentials
Government Officials/Law Enforcement	comply with any valid legal process, governmental request, or applicable law, rule, or regulation comply with legal requirements, as ordered by a court or if we believe in good faith that the law requires it; investigate, remedy, or enforce potential violations of applicable agreements; protect the rights, property, and safety of J. J. Keller, our clients and users, or others detect and resolve any fraud or security concerns	Personal Information Categories Identifiers Customer Records Legally Protected Characteristics Commercial Information Internet or Other Electronic Network Activity Information Non-Sensitive Geolocation Data Audio and Video Recordings Professional or Employment-Related Information Sensitive Personal Information Categories Account Log-In Credentials
Other Users	respond to a third party’s claim that content on our Site violates rights or requirements publish comments, review or other feedback posted to the public areas of our Site provide services to our clients on whose behalf you access, use, or interact with our Site protect the rights, property, and safety of J. J. Keller, our clients and users, or others detect and resolve any fraud or security concerns; investigate, remedy, or enforce potential violations of applicable agreements	Personal Information Categories Identifiers Customer Records Legally Protected Characteristics Commercial Information Internet or Other Electronic Network Activity Information Non-Sensitive Geolocation Data Audio and Video Recordings Professional or Employment-Related Information Sensitive Personal Information Categories Account Log-In Credentials

Your Choices

Cookies and Other Tracking Technologies

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:

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

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/.

How We Use Microsoft Ads

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.

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 webinfo@jjkeller.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.

Google Analytics and Google's Advertising Tools

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 use the following Google Analytics advertising features: Dynamic Remarketing with Google AdService, Google Dynamic Remarketing, and DoubleClick. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics opt-out browser add-on will not prevent us from using other analytics tools. Opting out will not affect your use of the Site.

How We Use Amazon Ads

We use Amazon’s advertising service, Amazon Ads, in connection with our Site to track the success of our ad campaigns with Amazon Ads. Amazon may collect or receive Personal Information about you through the use of cookies in connection with our use of Amazon Ads. To change your internet based advertising preferences with Amazon, please visit https://www.amazon.com/adprefs. To opt-out of cross-context behavioral advertising through Amazon, please visit https://www.amazon.com/privacyprefs?ref_=footer_iba. For more information about Amazon’s privacy practices, please see the Amazon Privacy Statement, available at https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ.

How We Use Firebase

Firebase is an analytics service provided by Google, Inc. We use Firebase in connection with one or more of our mobile applications to analyze button clicks and similar activities within those mobile applications. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their privacy policy: https://policies.google.com/privacy. We also encourage you to review Google’s information for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please review Google’s information about how Google uses data when you use Google’s partners’ sites or apps: https://policies.google.com/technologies/partner-sites.

How We Use Session Replay Services

Enabling session replay allows a website operator to record and play back a user’s journey through the operator’s website or mobile app. We use that software so we can better understand each individual user’s experiences on our Site (like how much time users spend on which pages, which links they click, what they like and don’t like) and use that knowledge to fix bugs on the Site, improve user experience on the Site, and improve how the Site functions.

We use session replay services offered by various Analytics providers, including Mouseflow, Inc. and screen and audio session replay services from Genesys Cloud Services, Inc. These session replay services use cookies and other technologies to collect data about the behavior of our users and their devices, in particular IP address of the device, screen size, device type (Unique Device Identifiers), information about the browser used, location (country only), preferred language for displaying our Site in addition to mouse movement, click information, and text you enter as you navigate through our Site. Our Analytics Providers store this information on our behalf in a pseudonymized user profile. Our Analytics Providers are contractually prohibited from selling the data collected on our behalf.

You can block session replay software in several ways. If you have cookies disabled, you won’t be tracked by any session replay software using cookies. You can visit www.allaboutcookies.org in order to obtain more information on deleting or controlling cookies. Some of our Analytics Providers also respect the Do-Not-Track (DNT) headers in browsers. As a website user browsing websites that utilize session replay, you are able to use the DNT setting in your browser to avoid certain Analytics Providers tracking any data about your visit. DNT is implemented through your browser, so you’ll need to check if the setting is enabled or disabled within your own browser.

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 Privacy 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.

Security

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.

Contact Us

If you have any questions about this Privacy Policy or the services, please contact us at: Email: Compliance@jjkeller.com; Phone: 1-833-933-0970.

Changes To Our Privacy Policy

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 Privacy 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.

Additional Privacy Rights for California Residents

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.

Sharing Information

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.

Identifiers
Commercial Information
Internet or Other Electronic Network Activity
Non-Sensitive Geolocation Information
Inferences

You have the right to opt-out of the sale or sharing of your Personal Information and can do so by clicking the button below.

We Do Not Use or Disclose Sensitive Information

We do not use or disclose sensitive Personal Information for any purpose other than our business purposes, as specified under the CCPA.

Your Rights and Choices

The CCPA provides consumers with specific rights regarding their Personal Information, subject to certain exceptions. If you live in California, this section describes your CCPA rights and explains how to exercise those rights.

Right to Know.

You 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 as required under the CCPA:

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, disclosing, sharing, or selling 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;
The categories of Personal Information that we sold, shared, or disclosed for a business purpose; and
The categories of third parties to whom Personal Information about you was sold, shared or disclosed for a business purpose.

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 comply with such request (and direct our service providers and other applicable third parties to do the same) unless an exception applies or the CCPA does not require us to do so.

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, or 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.

Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to opt-out if we sell or share Personal Information with a third party. To make a request, click the Do Not Sell or Share My Personal Information link on our Site, contact us using the information in the “Contact Us” section below, or click here:

Exercising Your Rights

In addition to any other options provided in this Privacy Policy, 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, mailing an inquiry to: J. J. Keller & Associates, Inc. Attn: Privacy Team, 3003 Breezewood Lane, Neenah, WI 54956, or completing the webform available here.

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. See the section titled "Using an Authorized Agent" below for more information. A parent or legal guardian may make a request on behalf of their child.

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.

When we receive your request to exercise your rights under the CCPA, we will: (a) acknowledge receipt of your request; (b) try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including Personal Information; and (d) consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

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.

For right to know requests, we will select a format to provide your Personal Information to you.

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.

Using an Authorized Agent

You have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If you choose to use an authorized agent, you must: (a) provide signed, written permission to that authorized agent to submit requests on your behalf; (b) verify your identity directly with us; and (c) directly confirm with us that you granted permission to the authorized agent to submit the request on your behalf. For clarity, you are required to verify the identity of both yourself and the authorized agent.

We may deny a request from an authorized agent if we do not have proof that they are authorized to act on your behalf.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, if you exercise your rights under the CCPA, we will not:

deny you goods or services;
charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
provide you a different level or quality of goods or services; or
suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your Personal Information and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Honoring Opt-Out Signals

We process opt-out preference signals (“Signals”) when you visit our Site. This means that you can opt-out of the sale or sharing of 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. We will display on our Site “Opt-Out Preference Signal Honored” when a browser, device or consumer using a Signal visits our Site, or display through a toggle or radio button that they have opted out of the sale or sharing of Personal Information associated with the applicable browser or device with third parties.

To set up a Signal, you can visit https://globalprivacycontrol.org/.

California Shine the Light

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.

Contact 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: Compliance@jjkeller.com
Postal Address:
J. J. Keller & Associates, Inc.
ATTN: Privacy Team
3003 Breezewood Lane
Neenah, WI 54956