Last updated: September 28, 2023
Effective date: September 28, 2023
1. About this Policy
For the purposes of this Policy, GJW is a controller (i.e., responsible party) for the practices described in this Policy. Additionally, this Policy does not apply to the extent we process Personal Data in the role of a processor or service provider (as applicable) on behalf of our business customers. For more information about the privacy practices of a GJW business customer or a customer affiliate, please contact the respective business customer directly. We are not responsible for the privacy or data security practices of our business customers, which may differ from those set forth in this Policy.
2. CALIFORNIA CONSUMER NOTICE OF COLLECTION
This Policy is provided to all California residents and any other applicable individuals subject to this Policy. To access specific sections of this Policy, you may use the following links:
3. COLLECTION OF PERSONAL DATA
When you use any of our Services, we may receive, and collect certain Personal Data. Some of this Personal Data is automatically generated and collected by us when you use our Services. Other Personal Data is provided to us at your option, or at our request, or collected about you by third parties. Below are instances of the Personal Data that we collect, categorized based on their type, and how they come into our possession.
(i) User information
We collect Personal Data about you that you choose to provide us, or that is generated by your device, when you sign up or register for Services that require registration ("User Information"), including the following:
(ii) Usage data
When you use our Services, data is generated from your use ("Usage Data"). Generally, there are two kinds of Usage Data—(a) technical or "log" data that is usually automatically generated by the operating systems, software, programs or devices involved in your use of our Services, and (b) use data, which is data that records and reflects how you interact with or use our Services, and the history of such use or interaction.
Our reception and collection of Usage Data is usually automatic. We, or our service providers, may also analyze such data to improve our Services, or to improve your experience in using our Services.
(a) Technical data
When you access or use our Services through a device, we may receive and collect the following technical data that is automatically generated from your access or use:
(b) Use data
We may receive and collect data that tells us how you use and interact with our Services, and how we can improve our Service in light of this information. Such Usage Data includes the following:
(iii) Information from third party sources
We sometimes work with partners in delivering our Services to you. As such, we may receive and collect Personal Data from our partners, such as when you use our Service through or in connection with our partners. The following are some examples of Personal Data that we may obtain from third parties:
(iv) Cookies and similar tracking technologies
(a) Cookies on the Website
Cookies are small text files containing information that websites transmit to your browser when you visit a website. Cookies serve a variety of functions, such as remembering your device, preferences and past navigation activities, and ensuring that the ads you see are more relevant to you and your interests.
Some of these cookies are deleted once you close your browsers (i.e., session cookies), while others may stay on your device for a certain period of time, until you delete them (i.e., persistent cookies).
Cookies on our Website are generally divided into the following categories:
|Cookie/Technology||Use and Purpose|
|Essential Cookies||These cookies enable you to use certain features of our Service that you requested. Without these essential cookies, the Website will not perform as smoothly for you as we would like it to, and we may not be able to provide the Website or certain services or features you request. Some of these cookies are used to authenticate your log in information, and for online checkout when you purchase items through our Service.|
|Analytics Cookies||Analytics cookies provide us with information regarding how visitors navigate and interact with our Website. Such cookies allow us to understand, for example, more about how many visitors we have to our Website, how many times they visit us and how many times a user viewed specific pages within our Site.|
|Targeted advertising cookies||These cookies record information about the history of your interactions with our Services. Such information speaks to your browsing and usage habits, and in turn, helps us to deliver advertisements, promotions or recommendations that are relevant and of interest to you. These cookies may be used by us or, with our permission, our business or advertising partners.|
|In-app tracking methods||We may use tracking technologies in mobile applications, that may use device identifier information, other identifiers such as "Ad IDs" to associate app user activity to a particular app, and to track user activity across apps and/or devices. Such technologies help us deliver Services that are personalized to you.|
(b) How you can manage your cookie and tracking options
4. PURPOSE FOR THE COLLECTION AND USE OF PERSONAL DATA
We collect or use your Personal Data in order to perform our contractual obligations, to comply with the law, or to protect certain vital public interests, as described in greater detail below. In other circumstances, we will only collect or use your Personal Data with your consent, or when we have a legitimate interest in doing so.
In the following, we explain why we use or collect certain Personal Data:
Legal Basis for Collecting and Using Personal Data
GJW relies on the following legal grounds for the collection, processing, and use of your Personal Data:
There is legitimate interest to process your Personal Data when the collection or use of certain Personal Data brings a clear benefit to you, to us or a third party, when such collection or use has little risk of infringing your privacy, and when it is reasonable to expect that the Personal Data would be collected or used in that way. Whether there is a legitimate interest is context specific, and you may contact GJW as stated in the “Contact Us” section below to request further information about our legitimate interest in processing your Personal Data, to the extent applicable.
The provision of your Personal Data is partly a statutory requirement and partly a contractual obligation.
5. DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES
Other than as described in this Policy, we do not sell Personal Data unless we have your consent or as otherwise permitted by applicable law. Otherwise, we may disclose Personal Data to third parties in the following ways:
6. WEB BROWSER UNIVERSAL OPT-OUT SIGNALS
At this time, GJW is not subject to the laws that require recognition of universal opt-out mechanisms. For that reason, this Website is not currently configured to recognize universal opt-out signals, though you may opt-out of the use of behavioral advertising cookies by following the instructions included below under the subsection entitled “Cookies and Similar Tracking Technologies” above.
7. YOUR RIGHTS AND CONTROLS TO YOUR PERSONAL DATA
The privacy laws applicable in different jurisdictions confer certain rights over your Personal Data. The rights available to you depend on our reason for processing your Personal Data and the requirements of applicable law. Depending on where you are located, you may have the following rights:
In addition to the rights listed above, you may also have the following options available:
If you choose to assert any of the rights described above, we will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations. If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. Under local law, you may be entitled to lodge a complaint with your local data protection authority, such as your state Attorney General’s Office.
Your rights and our responses will vary based on your state of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.
We do not discriminate against individuals who exercise any of their rights described in this Policy. However, we may require use of your Personal Data to provide access to the Services. Therefore, when you exercise your deletion right, in particular, you may lose access to certain aspects of the Services that require your Personal Data.
Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. If you designate an authorized agent to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.
The verifiable consumer request must:
Our verification process may also include a request for additional information to confirm your identity or your authorized agent’s identity (such as your name, email address and date of birth) or to obtain proof that you have given your authorized agent permission to act on your behalf. If our verification process is successful, we will respond to your request within the time and in the manner required by applicable law. If we cannot validate the identity of you and/or your authorized agent or obtain proof that you have given your authorized agent permission to act on your behalf, we will attempt to contact you to inform you. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm that the Personal Data relates to you.
We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will deliver our written response by mail or electronically, at your option. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the Personal Data from one entity to another entity without hindrance, such as by electronic mail communication. Further, if you would like to appeal any decision we make about your request, you may contact us as stated in the “Contact Us” section below.
8. OUR DATA RETENTION POLICIES
How long we retain your Personal Data depends on the context in which, and purposes for which, we collected it. We only keep your Personal Data for as long as necessary to fulfil the purposes described in this Policy, for which such Personal Data is collected, or as otherwise permitted under applicable law.
When we have no ongoing business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
9. HOW WE KEEP YOUR DATA SAFE
We are committed to protecting your Personal Data. To this end, we implement the appropriate technologies and policies, such as encryption, rigorous authentication measures, anonymization of your data where appropriate, and strict retention and deletion policies to prevent unauthorized and unintended access, use and disclosure of your Personal Data.
Do note that the protection of your Personal Data is a joint effort between you and us. We encourage you to protect your account by using a strong password, and keeping that password confidential and secure. Remember to log out once you have finished using our Services.
We are also committed to improving our privacy protection and data collection practices. In this vein, we welcome any concerns, feedbacks or recommendations that you may have with our data collection practices, which you can communicate to us through our customer support or by contacting as described in the “Contact Us” section below.
10. LINKED THIRD PARTY WEBSITES
We may provide links to other third party websites through the Services solely as a convenience to you. However, such linking does not mean, and should not be interpreted to mean, that GJW endorses, is affiliated with or makes any representations concerning such third party websites. GJW neither reviews, controls, nor is responsible for these third party sites or any content therein. By using such links, you will leave the Services. If you decide to access any of the third party websites linked to the Services, you do so entirely at your own risk. GJW shall not be liable for any consequences arising from use of any third party websites to which the Services link.
11. TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES
In course of providing our Services to you, we may disclose your Personal Data to our affiliates or partners in other countries where privacy and data protection laws are less rigorous than those that apply where you live, or which governs our business.
When this happens, we take certain measures to raise or enhance the security of the data transferred to these countries. For instance, we may employ standard contractual clauses with these international partners, and require them to accord your Personal Data with safeguards and protections equivalent with those applicable in the European Union or the United Kingdom.
We will not knowingly transfer your Personal Data to places where there are no adequate controls or legal safeguards possible to ensure the protection and security of such data.
12. OUR POLICIES ON PERSONAL DATA OF CHILDREN
This Policy does not apply to children under the age of 13 years, or who is of an age that makes it illegal for us to collect or process their Personal Data, or which only allows us to collect or process their Personal Data with parental consent.
We do not knowingly collect Personal Data of any child described above, without parental consent, where such consent is applicable. If you are under the above described age limit, or if you do not have parental consent where such consent is necessary, do not use our Services, and do not provide your Personal Data to us.
If a child provided this Website with Personal Data, we ask that a parent or guardian send us a written request to the address listed below and we will promptly delete the child's Personal Data from our records.
13. CHANGES TO THIS POLICY
We may make changes to this Policy from time to time. The revised Policy will be effective immediately at the time of posting, unless a later effective date is expressly stated therein. We will also revise the "Last updated" date stated above. Where such changes are significant or material, we will bring such changes to your attention through a prominent notice that we consider appropriate, such as by sending you an email or in-app notification.
It is your responsibility to periodically review this Policy. Users are bound by any changes to this Policy by using our Services after such changes have been first posted. If you do not agree to the new posted Policy, your only remedy is to discontinue use of the Website.
14. CONTACT US
For any questions or assistance with the content or implementation of this Policy, you may contact our Data Protection Officer by any of the following ways:
33 Fulton St
Middletown, NY 10940