Effective Date: July 1, 2020
Personal Information We Collect:
- Personal information you provide us on a voluntary basis, such as your contact information and any information you provide us through JOFI assessment tools.
- Information about you from third party sources such as your employer or potential supplier and service providers.
- Information automatically collected that your browser or mobile device shares.
How We Use Your Personal Information
- To create and maintain your account.
- To provide you and/or your Sponsoring Organization with information based on your responses to our assessment tools.
- To help us improve our Site, understand its users and their preferences, and to market our services.
- To protect our business interests or the rights of others, when required by law, to cooperate with law enforcement, or in connection with the sale or merger of all or part of our business.
How We Share your Personal Information
We do not share your personal information with third parties without your consent, except in the following circumstances:
Employers and Sponsoring Organization. We share the results of assessments with employers or other third party organizations who paid for the use of the JOFI Assessment Management System (JAMS) or otherwise made the JOFI Assessment available to you (“Sponsoring Organization”).
Service Providers. We may share your personal information with third party companies and individuals as needed for them to provide us with services that help us with our business activities and to promote our services to you. A list of our current service providers is available upon request.
Business Partners. We may share your personal information with our business partners who offer a service to you jointly with us. A list of our current business partners that have access to certain personal information we collect is available upon request.
Security, Compliance, Fraud Prevention, Safety; Compliance with Law.We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties for the purposes described above under the following sections: For compliance, fraud prevention and safety and for compliance with law.
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.
What are Cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies.” Cookies set by parties other than the website are called “third party cookies.” Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
What Cookies and Other Tracking Technologies do We Use? We use several different kinds of cookies on this Site, including strictly necessary cookies, which are cookies that are necessary for the Site to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Site; and functional cookies, which enable the Site to provide enhanced functionality and personalization. Specifically, the cookies we use are:
|ajs_user_id||The cookie is set by Segment.io and is used to analyze how you use the website||Analytics|
|ajs_group_id||This cookie is set by Segment.io. The purpose of the cookie is currently not identified.||Other|
|ajs_anonymous_id||This cookie is set by Segment.io to check the number of new and returning visitors to the website.||Analytics|
Cookies are not the only way to track visitors to a website. We may use similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Sites. These technologies often depend on cookies to function properly, and so disabling cookies may impair their functioning.
How Can You Disable Cookies and Other Tracking Technology? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit http://www.allaboutcookies.org and www.youronlinechoices.com.
Some Internet browsers also may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Other Important Privacy Information
Security. The security of your personal information is important to us. We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.
International Data Use. We are located in the United States and may have affiliates and service providers in other countries. Your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.
Verifying, Changing, and Deleting Your Information. If you have registered for an account through our Site, you can access, review and manage many changes yourself via your account, including updating your profile information and changing your communication preferences. If the information you are seeking is not available within your account, you can contact us as detailed below and ask us to change, update or fix your information in certain cases, particularly if it is inaccurate. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information).
Children. The Site is not intended for use by anyone under the age of 13, nor do we knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, you should not attempt to use the Site or send any information about yourself to us.
Notice to European Users
The following applies to individuals in the European Economic Area.
Legal bases for processing. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us using one of the methods detailed at the end of this Policy.
|Processing Purpose||Legal Basis|
|To provide the Site, communicate with you, create and maintain your account, and process your assessment.||You are subject to a contract with us and we need to use your personal information to provide services you have requested or take steps that you request prior to providing services.|
|To establish and administer accounts, issue invoices, and process payments and refunds.||You are subject to a contract with us and we need to use your personal information to provide services you have requested or take steps that you request prior to providing services.|
|To send you marketing communications. For compliance, fraud prevention, and safety.||These processing activities constitute our legitimate interests. We consider and balance the potential impact on your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|For compliance with law.||Processing is necessary to comply with our legal obligations.|
|With your consent.||Where we specifically ask for your consent to process your personal information, such processing is based on your consent. Where we rely on your consent, you have the right to withdraw it anytime in the manner indicated on the Site.|
Retention. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights. European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us as detailed at the end of this Policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Notice to California Residents
The following section applies to California residents.
(a) Shine the Light. Under California’s “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request please contact us as instructed in the “How to Contact Us” section and specify you are making a Shine the Light request.
(b) California Consumer Privacy Act (“CCPA”). The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.
Personal Information We Collect. We collect your personal information when you interact with our Site or otherwise communicate with us. For the purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device.
We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:
|Category of Personal Information Collected||Business Purpose of Collection|
|Identifiers, including name, email address, telephone numbers, and Internet Protocol (IP) address.|
To market and provide our services and assessment tools and to communicate with you.
In addition, we collect your IP address to provide you more relevant content, track Site visits, optimize your Site experience, and protect the Site.
|Assessment answers, scores, and related data||To provide our assessment tools and services to employers who purchase our services.|
|Browsing data||Improve Site performance and to provide enhanced functionality and personalization.|
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
Sharing Your Information. We disclose identifiers and your employment information with our service providers and Sponsoring Organization. We may also share your browsing data with internet service providers and data analytics providers.
Please note that we may collect, use and share additional personal information about you that is governed by laws other than the CCPA, and our activities related to such personal information are not disclosed here.
Directly from You. We collect identifiers and employment information when you:
- Create an account with us.
- Provide your contact information to us.
- Submit a request to us.
- Use our assessment tools.
Passively. We collect identifiers and browsing data passively when you:
- Visit and navigate our Site on any device.
- Receive or interact with our communications and Site that may contain cookies.
From Third Parties. We may receive identifiers and employment information about you from other sources. For example, we get information from:
- Our business partners, including online advertising networks.
- Your Sponsoring Organization.
Your Rights. The CCPA gives you certain rights regarding your personal information:
- Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
- Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions.
Exercising Your Rights. To exercise your rights above, please submit a request to us via this form or by emailing us at email@example.com or by calling us at 616-430-0828. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide the following information: name and contact information. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request. After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information.
We may not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request. We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. 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. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable.
We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. 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 prior to completing your request.
How to Contact Us
Metrics Reporting, Inc.
7063 Country Springs Drive
Bryon Center, MI 49315
United States of America
This policy was last updated: 7/1//2020