Effective Date: October 1, 2019
This Policy applies to all JITSUIN’s operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch of JITSUIN that we may subsequently form.
3. TRANSPARENCY/NOTICE—Types of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with JITSUIN and the requirements of applicable law. Some of the ways that JITSUIN may collect Personal Information include:
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
JITSUIN collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees (collectively “Individuals”).
3.2 How JITSUIN Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested. JITSUIN may use information about you to fulfil requests for products, Services, or information, including information about potential or future Services, including to:
Information We Process on Behalf of Our Commercial Customers
If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with JITSUIN to use the Services to host or Process this data (e.g., your employer). Our commercial customers control the Personal Information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our commercial customers to address any concerns you may have, in accordance with the terms of our contract with them.
JITSUIN may use Personal Information about you for its administrative purposes, including to:
Marketing JITSUIN Products and Services.
JITSUIN may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. JITSUIN may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below.
Research and Development.
JITSUIN may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, JITSUIN may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing.
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on JITSUIN’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6
Services via Mobile Devices.
Anonymous and Aggregated Information Use.
JITSUIN may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access JITSUIN’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and JITSUIN may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within JITSUIN and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues.
JITSUIN’s Services may offer various tools and functionalities. For example, JITSUIN allows you to provide information about your friends through our referral Services. Our referral Services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by JITSUIN or any other Third Parties for any other purpose.
JITSUIN may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Our uses of such Technologies fall into the following general categories:
If you would like to opt out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites, Social Media Platforms, and Software Development Kits
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and JITSUIN does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
JITSUIN’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such Third-Party services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
We may use Third-Party software development kits (“SDKs”) or APIs, as part of the functionality of our Services. Third-Party SDKs may allow Third-Parties, including advertisers, to collect your Personal Information to provide content that is more relevant to you. You may opt out of tracking by following the instructions below.
4. Human Resources Data
JITSUIN collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
5. Onward Transfer - JITSUIN May Disclose Your Information
5.1 Information We Share
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
5.2 INTERNATIONAL Data Transfers
You agree that all Personal Information collected via or by JITSUIN may be transferred, Processed, and stored anywhere in the world, including but not limited to the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to JITSUIN, you explicitly consent to the storage of your Personal Information in these locations.
6. Opt-Out (RIGHT TO OBJECT TO PROCESSING)
6.1 Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
6.2 Mobile devices
JITSUIN may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile or other devices. JITSUIN may also collect location-based information if you use our Site. You may opt out of this collection by changing the settings on your mobile or other devices.
6.3 Human Resources Data
With regard to Personal Information that JITSUIN receives in connection with the employment relationship, JITSUIN will use such Personal Information only for employment-related purposes as more fully described above. If JITSUIN intends to use this Personal Information for any other purpose, JITSUIN will notify the Individual and provide an opportunity to opt out of such uses.
6.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6.5 Cookies and Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. See http://www.networkadvertising.org/mobile-choice.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our Third-Party advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/, http://youradchoices.ca/choices/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
7. Rights of Access, Rectification, Erasure, and Restriction
Although JITSUIN makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which JITSUIN is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If JITSUIN determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, JITSUIN will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
8. Data Retention
9. Security of Your Information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
10. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
11. Children’s Privacy
The Services are not directed to children under 16 years of age, and JITSUIN does not knowingly collect Personal Information from children under 16 years of age. If you learn that your child has provided us with Personal Information without your consent, you may alert us as described below. If we learn that we have collected any Personal Information from children under 16 years old, we will promptly take steps to delete such information and terminate the child’s account.
12. Redress/Compliance and Accountability
13. Other Rights and Important Information
13.2 California Privacy Rights
The following capitalized terms shall have the meanings herein as set forth below.
15. Contact Us
If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request through our website contact form or to the data controller of your Personal Information:
Jitsuin, Inc. Legal Team
910 Campisi Way, Suite 2E, Campbell, CA 95008, USA
Copyright © 2019 Jitsuin - All Rights Reserved.