This Policy describes the way that Jaros, Baum & Bolles (“JB&B” or “We”) collects and uses the personally and non-personally identifiable information that it collects on websites that it owns, controls or uses (collectively, “Site”).

Information About Us
www.jbb.com is a site operated by JB&B.

We are committed to protecting and respecting your privacy. We are responsible for protecting your personal information as a “data controller” under applicable data protection legislation. If you have any queries about this Privacy Policy or how we use your personal information, please contact us by writing to us at privacy@jbb.com.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing or using our Site, you agree to the practices described in this Privacy Policy, which may change from time to time at JB&B’s sole discretion. Your continued use of this Site after we make changes is deemed to be an acceptance of those changes, so please check the Privacy Policy periodically for updates.

This Policy is prepared in compliance with the requirements of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and local, state and federal laws as in force from time to time. Where a particular provision applies to EU-based users only, we have made this clear. Our nominated person for data protection is Jay Conti, Chief Technology Officer, and the contact details are privacy@jbb.com.

Protecting your personal privacy is very important to us at JB&B. Below you will find a statement of our commitment to ensuring the privacy of your personally identifiable information (information you provide to JB&B which personally identifies you, listed in information we collect, or other identifying information). This Privacy Policy statement is applicable to the Site and all of our other communications and data processing platforms.

Information We Collect
The information we collect about you may personally identify you and thus might include your full name, postal address, email address, telephone number and identification numbers.

The types of information we collect include:

• Information you provide to us. Information provided by creating an account or paid membership on the Site, contacting us through the Site, or via email, including your name, address, email address, phone number, and credit card information.
• Automatically collected information. When you access our Site, some information not associated with specific users, such as device type, location information, IP address, webpage traffic, and access time is automatically collected in order to ensure the Site’s functionality.
• From third-party sources. We may collect information from third parties to whom you have provided your information (for example, through social media). Please note that if you choose to share information about yourself in an open format, such as through a third-party Site like Facebook, X, or LinkedIn or in the user-generated content elements of our own Sites, we consider that information to be public information – and not personal information.

We obtain personal information when you provide this to us via:

• Electronic or written responses to letters, mailings, and other means of communication. We may record emails and other correspondence if you contact us, for quality assurance purposes.
• During the course of providing our services to you, for instance, when you become a registered user of the Site. In order to become a registered user of our Site, you will need to share some personal information, such as your name and email address. Once you register, you will have an account with us and a password to access that account.
• Certain content submissions, community postings (i.e., chats or bulletin boards), or comments and suggestions.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your use of our Site, including your browser type or the Internet Protocol (“IP”) address used to connect your computer to the Internet.
• Your use of our Site, such as which pages you visited most often and which services, events or facilities are of most interest. We may also track which pages you visit when you click on links in emails. We may use this information to personalize the way our Site is presented when you visit it, to make improvements to our Site and to ensure that we provide the best service for users. Wherever possible, we use aggregated or anonymous information that does not identify individual visitors to our Site.

Why We Collect Information
We collect this information for the purposes described in the section titled “How We Use Information”. The lawful basis for which we process your information is:

• your consent: where you have provided your consent for the processing of your personal information;
• processing is necessary for the performance of a contract to which you are a party. If you fail to provide this information, we may be unable to perform the contract;
• processing is necessary for compliance with our legal obligations, for example, when responding to a public or governmental authority, courts, or regulators, according to a legal obligation under applicable law;
• processing is necessary for the purpose of the legitimate interest pursued by us or a third party, except where your rights as a data subject override our legitimate interest.

How We Use Information
We may use your personal information:

• to provide you with services or information you have requested;
• to provide you with information about services we think may be of interest to you; and
• to notify you about changes to our services; as part of our efforts to keep our Site safe and secure; and to ensure that content from our Site is presented in the most effective manner for you and for your computer.

If you are based in the EU, we will only use your personal information for electronic marketing purposes if we are allowed to do this by law or if we have your consent. If you agree to us providing you with marketing information, you can always opt out at a later date. If you would rather not receive marketing materials from us, please let us know at any time by contacting us using the details at the end of this Policy.

We will never disclose your personal information to a non-affiliated third party without first receiving your permission.

JB&B will never willfully disclose any personally identifiable information about our visitors to any non-affiliated third party without first receiving the user’s (or if a child, the parent’s or guardian’s) permission. We do not collect personally identifiable information from our visitors other than what is supplied to us on a voluntary basis. Visitors may provide personally identifiable information to JB&B via (1) electronic or written responses to letters, mailings and via our newsletter, and (2) during the course of providing our services to you. In addition, personally identifiable information may be voluntarily provided by the user in connection with certain content submissions, community postings (i.e., chats or bulletin boards), comments and suggestions, or voting.

This Site may make available to its users chat rooms, forums, message boards and/or news groups. Any information that you disclose in these areas becomes public information and you should exercise extreme caution when deciding to disclose such information. JB&B may use such information for its internal purposes including, but not limited to, editorial feedback, auditing, research and analysis in order to maintain, protect and improve the Site and the other goods and services offered or provided, marketing and promotional purposes. JB&B may also use this information to deliver to you information about JB&B and for trend analysis, pattern detection and site administration. In addition, JB&B may collect IP addresses for the purposes of system administration and to report aggregate information to our advertisers. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web. JB&B does not link IP addresses to anything personally identifiable, so your use of our Site remains anonymous.

JB&B may share your personal information with companies that are related to or affiliated with JB&B (collectively, “Affiliates”). Affiliates will use your personal information in accordance with the terms of this Privacy Policy.

Users may opt-out of receiving future marketing communications from JB&B and other entities by clicking the unsubscribe button at the bottom of every email or emailing us at privacy@jbb.com.

Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), JB&B will never knowingly request personally identifiable information from anyone under the age of 13 without requesting parental consent. Only persons 13 and older may provide personally identifiable information to JB&B. Persons 13 and younger may visit the Site, but may not register or otherwise provide any personally identifiable information.

If you are based in the European Union, the above provisions relating to children’s privacy generally apply to children under the age of 16, but this may vary across different member states.

How Long We Keep Your Personal Information
We keep your information for no longer than is necessary. We will retain your information for any period required by law, and where we are not under a legal obligation to retain your information, we will determine what is necessary by reference to the lawful basis for processing set out above and our legitimate interests.

If you have any questions about how long we keep your information, please contact us.

California Privacy Rights
Please see our Privacy Notice for California Residents.

Your Rights Under Data Protection Law (If You Are Based in the EU) 
You can manage your marketing preferences by emailing us at privacy@jbb.com.

You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (“right of access”). You also have the right to be informed of the safeguards we have in place relating to any transfers of your information to another country.

You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (“right to rectification”). If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records.

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided us with changes, for example, if you change your email address, name, or payment details, please let us know using the contact details at the end of this Policy.

You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (“right of portability”). This right does not apply where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

You have a right to seek the erasure of your data (often referred to as the “right to be forgotten”). You may wish to exercise this right for any reason, for example where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. You should note that we are entitled to and reserve the right to retain your data for statistical purposes. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations or for reasons of public interest. You have a right to ask us to restrict our processing of your information (“right to restriction”) if:

• you contest its accuracy and we need to verify whether it is accurate.
• the processing is unlawful and you ask us to restrict use of it instead of erasing it.
  we no longer need the information for the purpose of processing, but you need it to establish or defend legal claims.
• you have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests.
• you exercise your right to restrict processing. We would still need to process your information for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons.
• you have a right to prevent us from processing your data for the purposes of marketing.

If you would like to exercise any of your rights above, please let us know using the contact details at the end of this Policy. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.

You have a right to report any of your concerns about our use of your data to the relevant data protection authority in your EU country.

International Transfers (EU-Based Users)
If you are based in the EU, we will need to transfer your personal information to the USA for the purposes listed in this Policy. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal information, and in compliance with the GDPR.

Technical Information
To enable our systems to recognize your browser or device and to provide and improve our products and services, we use cookies and other technologies. Cookies are pieces of information that a website transfers to an individual’s hard drive for recordkeeping purposes. Cookies make Web-surfing easier for you by saving your subscription information and personal preferences while you are at our Site. The use of cookies is an industry standard, and you will find cookies at most major websites. Cookies also help JB&B to see which areas are popular and which are not popular and allow JB&B to make improvements and updates to the Site based on such data as total number of visitors and pages viewed. This information is most easily tracked with cookies.

Log Files – JB&B may use log files to track how our sites are being accesses and used. Log files track anonymous user information such as IP addresses, browser types, internet service providers, referring and exit pages, platform type, date and time stamps, and number of clicks to, from, and within our sites.

Information from Banner Ads – If you arrive at the Site through a banner ad or other Affiliate referral device, JB&B may track from where you arrived as well as clicks that might have impacted our servers.

JB&B may use clear GIF tracking pixels to track user movement through our Site for aggregated site traffic measuring. In addition, some Affiliates may set such tracking pixels on our pages to track completed forms and requests referred by their websites.

JB&B, either directly or via its agents, may employ persistent cookie, web beacon or other technology (collectively, “Analytics Technology”) that tracks unique users on the Site. The data collected by the Analytics Technology includes, but is not limited to, User ID, IP Address, User Agent, Date/Time Stamp, Referral URL, Request URL, Review Submission ID, Client Name or ID, Product Category ID, Product ID, Website Category, Session ID, Click Events, Conversions, Site Visits, Average Time on Site, and other data passively generated by a user’s interaction with the Site.

Most browsers are initially set to accept cookies. If you prefer, you can change your browser settings to refuse cookies. However, in so doing, you may not be able to fully utilize the Site or may experience difficulties accessing parts of the site.

You may opt out of the collection of user data via the Analytics Technology by following the directions at privacy@jbb.com.

Security
Our Site has industry-standard security measures in place to protect the loss, misuse and alteration of the information under our control. Although there is no “perfect security” on the internet, JB&B will take all reasonable steps to ensure the safety of your personal information.

Third-Party Software
JB&B’s services, including JB&B EnviroDocs^TM, use a QR Code Generator powered by Bitly, which is governed by the privacy policy found here: https://www.qr-code-generator.com/company/privacy-policy/.

Hyperlinked Sites
No hyperlinking is permitted to the Site without the express written permission of JB&B.

Wireless Communications
If the email address you provide to JB&B is a wireless address, you agree to receive messages at such address from JB&B. You understand that your wireless carrier’s standard rates apply to these messages. You represent and warrant that you are the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges associated therewith.

Intellectual Property
Your use of the Site does not give you permission to use any of JB&B’s names, logos, designs, slogans, product trademark or service marks (“JB&B’s Marks”) in any manner, or to use JB&B’s Marks or any other words or codes in any “metatag” or to use other information location tools to identify and select sites, without JB&B’s express written permission for a particular use.

Use of the Site
You acknowledge that the personal information you provide to JB&B is collected and stored in the United States and therefore consent to the transfer of information to and storage of the information in the United States, regardless of your country of domicile.

Severability
If any provision of this Privacy Policy is found to be illegal, void or unenforceable, that provision will be deemed severed from the balance of the agreement and will not affect the validity and enforceability of the remaining provisions, which will continue in full force and effect.

Acknowledgement
By completing forms provided by JB&B and providing personal information through the Site, through any means of communication with JB&B or by using the Site and services contained therein, you hereby represent and warrant that:

• you have read, understand and agree to JB&B’s Privacy Policy;
• you are an actual person of at least 18 years of age, you have the right to provide the information that you submit to JB&B, and the information you submit is accurate, complete and truthful; and
• if you do not agree to the terms of this Privacy Policy, then do not provide your information to JB&B through any means. In such case, JB&B is relieved of any of its obligations to you as set forth in this Privacy Policy.

Revisions
JB&B may, at its sole discretion, revise this Privacy Policy at any time in a manner consistent with applicable laws and regulations. When we revise this Policy, including changes to JB&B’s use of your personal information, we will incorporate the revisions into this Policy and will revise the “last revised” date at the top of this web page. We recommend that you review those changes in order to remain informed about how JB&B uses your personal information.

If you have any comments, questions or requests, wish to address a complaint or exercise your rights, please write to privacy@jbb.com.