Last updated: March 2020
Information We Obtain
We may obtain the following categories and types of personal information when you choose to provide it through our Site:
- Contact information— such as your name, postal address, email address and telephone number;
- Site information— personal information you provide on or through our Site; and
- Biographical information— such as information about your education, work and military history, legal work eligibility status, and other information relevant to specific jobs for which you may apply.
In addition, when you visit our Site, we may collect certain information by automated means, such as cookies and web beacons. The information we obtain in this manner may include IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website and other actions taken on such website. As the visitor clicks through the website, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.
An example of such third party is Google Analytics, which we use to collect and analyze demographic and other information, and through which Google will collect certain information to be used according to Google’s privacy practices. To opt-out of the use of Google Analytics, click here.
Information about our cookie practices is available here. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.
How We Use the Information We Obtain
We use the information we obtain through the Site to:
- respond to and communicate with you about your requests, questions and comments;
- operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services and Site; and performing accounting, auditing, billing, reconciliation and collection activities);
- perform data analyses and other processing (including market and consumer research and trend analysis);
- protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
- comply with and enforce applicable legal requirements, relevant industry standards and our policies.
In addition, we use information collected online through cookies, web beacons and other automated means for purposes such as (i) customizing our users’ visits to our Site and (ii) providing services to you. We also use this information to help diagnose technical and service problems, administer our Site, identify users of our Site, and gather demographic information about our users. We use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Information We Share with Third Parties
We do not sell or otherwise share personal information about you, except as described in this Online Privacy Notice.
- We share personal information with third parties who perform services on our behalf. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
- With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Junction 37 is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
- We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, bankruptcy or liquidation).
We offer you certain choices about how we communicate with you and what information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated below.
Pursuant to Section 1798.100 – 1798.199 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. To request a list of companies, if any, to which Junction 37 has provided personal information for its own marketing purposes, please email us at email@example.com. Please allow 30 days for a response.
We have put in place reasonable physical, electronic and managerial procedures to safeguard the information we collect; however, due to the inherent open nature of the Internet, we cannot guarantee that all information will be free from unauthorized access by third parties, such as hackers, and your use of the Site demonstrates your assumption of this risk.
We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for satisfying any legal, accounting or reporting requirements or to comply with our data retention practices.
If you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”), the following additional sections apply:
- Grounds for Using Your Personal Information: we rely on the following legal basis to process your personal information:
- It may be necessary for us to use and disclose your personal information for the performance and fulfillment of the contract between us and to provide you with our services;
- We may use and disclose your personal information where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
- If you specifically consent to certain uses of your personal information, we may use your personal information in a manner consistent with that consent; and
- We will also process, transfer, disclose and preserve personal information when we have a good faith belief that doing so is necessary.
- If applicable pursuant to the GDPR, you have the right to withdraw previously provided consent for our processing of your personal information by contacting us at firstname.lastname@example.org. Such individuals also have the following rights:
- Right to access— This right allows individuals to obtain confirmation that his or her personal information is being process and allows individuals to request details of the processing of his or her personal information, including, without limitation, categories of recipients to whom the personal information have been or will be disclosed and purposes of processing.
- Right to rectify— This right allows individuals to rectify any inaccurate personal information about him or her.
- Right to restrict processing— This right allows individuals to block or suppress processing of personal information under certain circumstances.
- Right to be forgotten— This right is also known as the “right to erasure.” It is an individual’s right to have personal information erased or to prevent processing in specific circumstances.
- Right of data portability— This right allows individuals to move, copy or transfer personal information from one place to another in a secure manner without interrupting the integrity and usability of the information.
- Right to object to processing— This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
To exercise any of the following rights, you may contact us at email@example.com
If you have an unresolved privacy or data use concern regarding the EU-U.S. Privacy Shield or Swiss-U.S. Privacy Shield Framework that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Junction 37 is also subject to the investigatory and enforcement powers if the U.S. Federal trade Commission.
Links to Other Websites
Our Site may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Junction 37. Linked websites typically have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with Junction 37, any use of those websites, or the privacy practices of those websites.
Updates to Our Online Privacy Notice
How to Contact Us
Junction 37, LLC
Attn: Legal Dept.
530 7th Avenue, Suite 1101
New York, NY 10018