Last modified: September 22, 2020
This policy describes the types of information We may learn about visitors and registered users (“You,” “Your”), both automatically and through voluntary actions You may take, when You visit the website https://JDRefugee.com, its sub-domains, affiliated websites, parent site https://JDCareersOutThere.com, and any services available therefrom, including any mobile versions of the website or mobile applications (the “Site”) and electronic messaging between Us and You such as email. This policy also describes Our practices for collecting, using, maintaining, protecting and disclosing that information.
WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
We may collect several types of information from and about You, including:
- Information You provide to Us
- Information We collect through automatic data collection technologies
- Information provided by Our third party service providers (“Contractors”)
The information We collect may be:
- Personally identifiable information
Includes Your contact information such as Your name, company, email address, postal address and phone number, by which We may communicate with You online or offline.
- Non-personally identifiable information
Includes data that may reveal such things as the Internet protocol (“IP”) address assigned to Your computer, Your internet service provider, Your browser accessing the Site, the type of equipment You use to access Our Site, Your language, specific pages that You access on the Site or prior to or after visiting the Site, the content of undeleted cookies Your browser accepted from Us, the length of time You spend at the Site, and referring website addresses.
Information We collect from the different sources outlined above that is non-personally identifiable may in some cases be linked or combined with information we collect that is personally identifiable. We will refer to the information We collect as “personal data,” “your data,” “personal information,” or “your information.” Depending on the situation, personal data can refer to personally identifiable information and/or non-personally identifiable information.
Information You Provide to Us
Information We collect on or through Our Site that You provide to Us may include:
- Information You provide by filling out forms on the Site.
This includes information You provide when registering on Our Site to receive Our emails, registering on Our Site upon purchase of Our products and/or services, information You provide in requests for personal and/or technical help, and information You provide as a response to Our follow-up. This also includes information You post in Our interactive areas (please see the “Interactive Areas” sub-section below).
- Information You provide in response to surveys We may request for Our business research purposes.
- Information You provide when You contact Us, including Your email address and Our records and copies of that correspondence.
- Information You provide when You purchase products and/or services from Us.
We currently use Pay Pal and Stripe for merchant services, neither of which shares Your credit card information with Us. Your personal payment information is provided directly to them and governed by their privacy policies. We reserve the right to change Our merchant service provider(s) without notice to You.
You are under no obligation to provide Us with personal information, but without it We may not be able to provide to You the products or services that You request. We and Our Contractors may retain the content of and metadata regarding any correspondence You may have with Us or Our representatives, regardless of the mode of communication by which such correspondence was made.
We may also provide areas off of the Site, hosted by a third party, in the form of a community discussion board that allows users to post comments and other materials. These interactive areas are intended to enhance the user experience for Our members and class registrants by providing an online community. Like the interactive areas on the Site, JDCOT is not liable for information posted in Our interactive areas on such third party products or services. We advise You to review the privacy policies of any third party interactive areas/community discussion boards that are off Our Site.
Information We Collect Through Automatic Data Collection Technologies
As You navigate Your way through and interact with Our Site, We may use automatic data collection technologies to collect:
- Information about Your computer and internet connection such as Your Internet protocol (“IP”) address assigned to Your computer, Your internet service provider, Your operating system, Your location, and Your browser accessing the Site.
- Information about Your visits to Our Site, including specific pages that You access on the Site or prior to or after visiting the Site, the content of undeleted cookies Your browser accepted from Us, the length of time You spend at the Site, and referring website addresses.
The information We collect automatically will not include personally identifiable information. We use this data as statistical data for purposes including estimating Our audience size and usage patterns, and determining popular areas of the Site. This statistical data helps Us to improve Our Site, provide a better user experience and a better service that is more customized to Our audience. To the extent that You voluntarily provide personally identifiable information to Us, We may connect this information to personally or non-personally identifiable information about You that You provide to Us or We collect from other sources.
Information We collect through automatic data collection technologies may be provided to Us by Our third party Contractors. For example, as with many other websites, Our Contractors include Google Analytics for Site analytics. Additional analytics may come from companies including Our Site’s web hosting company, Liquid Web, as well as Our email communications companies, Aweber and SendGrid.
- Technologies We use for automatic data collection may include:
Like other commercial websites, Our Site uses a standard technology called “cookies”. Cookies are small information files stored by Your web browser on Your device’s hard drive when You visit a website. Cookies allow for the collection of non-personally identifiable information.Our Site may send one or more cookies to Your hard drive to enable Us to enhance Your user experience with the Site by storing user preferences and tracking user trends. You may refuse to accept cookies by adjusting the settings on Your browser or internet security program accordingly. If You disable cookies, You may not be able to access the full functionality of Our Site.
- Pixels / Web Beacons
Like other commercial websites, Our Site and emails use a standard technology called “pixels” or “pixel tags” or “web beacons”. These are small electronic files that trigger a cookie and permit Us to track how many users have visited specific pages or gather other statistics such as email opens (via Our current Contractor, Aweber).We may also use this technology in the form of social media pixels (e.g. using the Facebook pixel on Our Site). These pixels allow social media sites to track their visitors to outside websites like Our Site so they can tailor the advertising messages their users see while visiting their site. These pixels also allow Us to develop, improve and target Our promotional messaging to You both on Our Site and social media sites. We reserve the right to use these technologies in compliance with the policies of the various social media sites. For more information on social media advertising and tracking, as well as opting-out, please see the “Advertising” sub-section below.
Our Site may contain links to other websites and We may include or offer third party products or services via links, affiliate links or advertisements. The third parties being linked to or serving the content, applications or advertisements may use tracking methods, including cookies, to collect information about You when You use Our website, including how You view or interact with their offers or advertisements. The information third parties collect may be associated with Your personal information or they may collect information, including personal information, about Your online activities over time and across different websites and other online services. They may use this information to provide You with interest-based (behavioral) advertising or other targeted content.
Google requires that We inform You of the Google Analytics features that We use and how We use them, even if the information may be repetitive from what is already listed in this Policy.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. The data they collect is shared with other Google services (e.g., YouTube, which We also use). Google may use that collected data to contextualize and personalize the ads of its own advertising network.
Google Analytics provides Us information on how You interact with and use Our Site. This data does not identify You, but it may provide Us with key demographic information such as age, gender, and other information about Our visitors and subscribers. This feature also provides Us with data on how long Our visitors and subscribers use Our Site, which pages they use most, and how they found Our Site. We may also use the Google Analytics service for marketing the Site and for placing advertising that is targeted to You on the Site and other sites that You visit.
When You visit Our Site, Google Analytics plants a cookie on Your web browser to identify You as a unique user during subsequent visits to Our Site. You can prevent Google Analytics from recognizing You by disabling cookies in Your browser. You can learn more about how Google collects and uses data here, and their privacy practices here.
HOW WILL WE USE YOUR INFORMATION?
We and Our Contractors may use information We collect about You to:
- provide customer support
- manage Your account
- improve the Site, Site traffic and user experience, as well as content, materials, and services that We make available on the Site
- deliver the products and services You request and that We think You want most
- allow You to participate in Our interactive features when you choose to do so
- communicate with You via email and other methods
- provide You with educational and general information, as well as offers and promotions about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information
- display advertising and content tailored to You on Our Site and other sites that You visit to remind You about Us (via Google Analytics, Facebook pixels and/or other services), including remarketing and retargeting Our Site, products, and services on other websites after You have visited Our Site (including advertising on Facebook and creating Facebook Lookalike Audiences)
- detect, prevent and address technical issues, and
- perform other functions or those described to You when You submit Your information.
Emails and Communications
When You submit Your email address to Us, You agree to receive email from Us. We use email to stay in touch with You and provide You with educational information, offers and promotions. We only send emails to people that have authorized Us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails. We are strongly opposed to spam (unauthorized commercial email delivery). Here is a link to the anti-spam policy for Aweber, the Contractor that collects and distributes Our newsletters and email communications.
If You have signed up to receive Our electronic communications and later wish to opt-out from receiving further emails, You may make this change at any time by clicking on the “Unsubscribe” link provided at the bottom of Our emails. You can also manage Your email contact information and which of Our topical email lists You participate in by clicking the “Change Subscriber Options” link at the bottom of Our emails. You can also make these changes by sending Your request to Us via the contact form on Our Contact Page.
We are committed to keeping Your e-mail address confidential. We will not sell, rent, or lease Your email address to third parties, and will not disclose Your email address to any third parties except as allowed in the “Disclosure of Your Information” section of this Policy. By submitting Your email address, You agree to allow Us to use Your email address for custom audience targeting on sites like Facebook, where We display custom advertising to specific people who have opted-in to receive communications from Us. For more information on social media advertising and tracking, as well as opting-out, see this Policy’s “Advertising” sub-section.
We will maintain the information You send via e-mail in accordance with applicable federal law. We may retain the content of Your email messages together with Your email address and Our responses.
After visiting Our Site, You may see Our advertising on sites such as social media sites including Twitter, Facebook, Instagram, and LinkedIn. This type of marketing that is tailored and targeted to You off of Our Site is sometimes referred to as remarketing or retargeting. Similar to other commercial websites, to accomplish this, We may use technology such as cookies, pixels, and/or Your email address. Any data that is shared with social media companies is only shared for this type of marketing on Our behalf and the companies using it are obligated not to disclose or use it for any other purpose. This data allows Us to improve Our marketing services by showing You Our ads on their sites and having Our ads presented to new audiences based on similar interests to Yours.
For example, Facebook and/or Instagram would link data collected via Us with Your account on their platform, allowing Us to serve You with advertisements on their platform. They call this Custom Audience targeting. They call the similar audience that they would deliver Our ads to a Lookalike Audience.
- You can visit LinkedIn’s Help Center to learn more about the practices and policies of LinkedIn and to opt-out from their interest-based advertising.
- The Digital Advertising Alliance is a nonprofit that establishes and enforces responsible privacy practices for relevant digital advertising. Many companies, including Facebook, adhere to the Self-Regulatory Principles for Online Behavioral Advertising and the opt-out programs established by the DAA. To opt-out of advertising from participating companies, You can visit the DAA by clicking here for the USA, here for Canada. and here for Europe, or opt-out using Your mobile device settings.
- The Network Advertising Initiative is the leading nonprofit self-regulatory association comprised of third party digital advertising companies and dedicated to responsible data collection and its use. Most ads served in the U.S. involve the technology of the NAI’s member companies. Like the DAA, the NAI has established an opt-out program where You can opt-out of advertising from participating companies by clicking here.
- You can click here to learn more about online advertising in general.
DISCLOSURE OF YOUR INFORMATION
We may disclose non-personally identifiable information about Our users without restriction.
- To Our Contractors, service providers, subsidiaries, and other third parties We use for the purpose of furthering Our mission as an organization and providing the Site and Our services to You. These third parties will have access to Your information only to perform their specific tasks on Our behalf and are obligated not to disclose or use it for any other purpose. These third parties include but are not limited to: web development/design companies, web analytics companies, advertising networks, shopping cart and email service providers. For details related to advertising, please see the “Advertising” subsection above.
- To any buyer or successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s asserts and/or business.
- To fulfill the purpose for which You provide it.
- If We have received Your express permission beforehand.
- If We believe release is necessary or appropriate to protect the rights, property, or safety of JDCOT, Our customers or others.
- If We believe release is necessary or appropriate to comply with any court order, law or legal process, including to respond to any government or regulatory request.
- For any other purpose disclosed by Us when You provide the information.
ACCESSING AND CORRECTING YOUR INFORMATION
You may send us an e-mail via the Site’s Contact form to request access to, correct or delete any personal information that You have provided to us. We may not accommodate a request to change information if We believe the change would violate any law or legal requirement or cause the information to be incorrect.
Also, as mentioned above, You can cancel Your participation in Our email lists at any time by clicking the “Unsubscribe” link included at the bottom of each email. You can also manage Your email contact information and which of Our topical email lists You participate in by clicking the “Change Subscriber Options” link at the bottom of each email.
HOW DO WE PROTECT INFORMATION COLLECTED ABOUT YOU?
Data protection is a high priority for JDCOT. We have put in place security measures (including physical, electronic, and corporate practices) to safeguard the storage and communication of the information You provide to Us and the information We collect automatically. These security measures include but are not limited to: working only with reputable third-party vendor Contractors, using password protected directories and databases to safeguard Your information, and SSL (Secure Socket Layer) technology to ensure that Your information is fully encrypted and sent across the Internet securely. We use the much-trusted PayPal and Stripe to handle financial transactions so that Your financial information is securely stored and encrypted by them. After a financial transaction on the Site, Your financial information will not be stored on Our servers. Only authorized employees and contractors are permitted access to Your information, and only for appropriate use such as providing service to You or managing Your account. Information is sent via encrypted channels and firewalls are in place to prevent unauthorized persons from gaining access.
The safety and security of Your information also depends on You. You are responsible for keeping Your passwords for accessing password-protected parts of Our Site confidential, whether You created the passwords or We gave them to You. We ask You not to share Your password with anyone. This also applies to passwords for any online community we offer that is not located on Our Site.
Unfortunately, the transmission of information via the internet is not completely secure. For example, email is not even recognized as a secure medium of communication. Although We have taken these and other steps, We do not covenant or guarantee that Your information will always remain secure from cyber-attack, other criminal events, or any circumvention of any privacy settings or security measures either at Our Site or those of Our Contractors. For any and all of these reasons, any transmission of personal information is at Your own risk.
LOCATION OF THIS SITE
This Site is hosted and operated in the United States. However, We and Our Contractors may, in Our effort to provide the Site, store Your information, including personal information, in the United States, or We may transfer it to, and store it within, other countries.
Those who access or use the Site from jurisdictions outside the United States do so at their own choice and risk and are solely responsible for compliance with local law. If You are not a resident of the United States, You acknowledge and agree that We may collect and use personal information about You outside Your home jurisdiction, and that We may store personal information about You in the United States or elsewhere.
YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
If You are within the European Economic Area (EEA), You are entitled to certain information and have certain rights under the General Data Protection Regulation (GDPR). We aim to take reasonable steps to allow You to correct, amend, delete, or limit the use of Your personal data. We may ask You to verify Your identity before responding to any such requests.
In certain circumstances, Your rights include:
- The right to be informed of what information We have about You by contacting us.
- The right to access, update, rectify or delete the information We have about You.
When possible, You can take this action Yourself. For example, You can Unsubscribe yourself from Our emails and edit which of Our email lists You participate in via links at the bottom of Our emails. As another example, You can change Your own password for logging in to the Site. When You can not perform these actions Yourself, please contact Us to request help.
- The right to object to and seek restrictions on Our processing of Your data.
- The right to the portability of Your data.
You have the right to be provided with a copy of the information We have about You in a structured, commonly used and machine-readable format.
- The right to withdraw consent.
For situations where We relied on Your consent for the processing of Your personal data, You have the right to withdraw that consent at any time.
- The right to lodge a complaint about Our collection and use of Your personal data with a supervisory authority that has jurisdiction over issues related to the GDPR.
We require only the information that is reasonably required to enter into a contract with You. We will retain any information You choose to provide to us until the earlier of: You asking us to delete the information, Our changing to a different data provider, or Our deciding that the value in retaining the data is outweighed by the costs of retaining it.
What Legal Basis Does JDCOT Have For Collecting & Processing Your Information?
If You are in the European Economic Area (EEA), Our Site must have a legal basis for collecting and processing Your personal information. Our legal basis is as follows:
- Your consent
As stated above, for situations where We relied on Your consent for the processing of Your personal data, You have the right to withdraw that consent at any time. In some cases, such as Our email communications, You can withdraw consent Yourself via the links at the bottom of each email. When You are unable to withdraw consent Yourself, You can do so by contacting Us via the form on Our Contact page.
To complete a new contract or fulfill an existing contract, personal data processing is necessary. For example, when You purchase a product or service on Our Site, that transaction forms a contact between Us and You. We then need to fulfill that contract by providing You with access to the product or service and all that comes with it. The pre-contractual sales process may also require the processing of personal data when, for example, You request more information from Us and We then communicate with You.
- Legitimate interest
A legitimate interest for processing Your personal information exists when You submit the information with the reasonable expectation that it will be processed and there is no undue impact on You that would override Our interests. We have a legitimate interest in, amongst other things, sending You information that You request, providing responses to Your questions, direct marketing to You, market research, network security, fraud prevention, and providing You with access to the Site and its features.
For more information with respect to GDPR, please contact Your local data protection authority in the European Economic Area (EEA).