Privacy Statement
and Your Privacy Rights

Effective Date: October 7, 2019 

This Privacy Statement (“Privacy Statement” or “Agreement”) is made by and between JM Family Enterprises, Inc., its subsidiaries and other affiliates (“JMFE”) and you, and explains what information we collect about you, what we do with it and how you can control your information. The Privacy Statement sets forth the terms and conditions that apply to your access and use of the Internet websites owned by JM Family Enterprises, Inc., located at the URL www.jmfamily.com and go.jmfamily.com (the “Websites”).

This Privacy Statement constitutes a binding agreement between you, as a user of our Websites, and us, as the owner of the Websites. BY USING our websites, OR ACCESSING OR REGISTERING ON OUR WEBSITES, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY STATEMENT, PLEASE DO NOT USE, ACCESS, OR REGISTER ON OUR WEBSITES.

Your use of our Websites is also expressly subject to our Terms of Use.

What We Collect

We collect information from you and your devices. We also receive information about you from third parties. We collect two types of information about you: “Personal Information” and “Non-Personal Information.”

“Personal Information” is data that can be used to uniquely identify or contact you. “Non-Personal Information” includes technical data that, alone, cannot be used to identify you and includes information about how you access and use our Websites. Please note that over time, non-personal information may become personal information due to regulatory developments, technological advancements, or the co-mingling of personal and non-personal information. Specifically, we collect the following information in the following ways:

• Registering with our Websites: We may collect personal information (which may include first and last name, home or other physical address, e-mail address, telephone number, driver’s license number account number(s) at a bank or financial institution, and job history information) about you or others when you voluntarily submit it to us, for example, as part of a job application or when you join a mailing list.

• Requests for information: If you submit feedback, questions or requests for information about our products and services, we may request your name, mailing address, telephone number and email address in order to respond to your inquiries. 

• Website browsing information:  When you visit any website, including our Websites, your browser may automatically send certain information such as browser type, browser language preference, operating system, internet service provider, IP address, device identification number, geo-location data, and online browsing data (like date and time of access to our website, referring website address, pages viewed, features used, links clicked, and other actions you take in connection with the website, sometimes referred to as “clickstream data”).
  
• Tracking information: When you visit our Websites, automated collection tools such as “cookies” and “web beacons” may gather Non-Personal Information about your visit and your computer.

• • A cookie is a small text file stored on your computer that lets us know whether you’ve visited the website before as well as your navigation experience during your visit. Cookies may be used to facilitate your access to our Websites, enhance and personalize your online experience, and recognize your computer or your device.  
  • Web beacons are small graphics placed on our Websites and in email communications that may be used to measure the effectiveness of our Websites and email communications. Web beacons on our Websites may collect information about your visit, like the pages you view, the features you use, the links you click and other actions you take in connection with our Websites. Web beacons in our emails may track your interactions with those messages, such as when you receive, open, forward or click a link in an email message from us.

• Google Analytics — To help facilitate the delivery of relevant content, we may use Google Analytics and Google Advertising Features, including Remarketing, Impression Reporting, Demographics, and Interest Reporting. Google Analytics uses cookies to report on user interactions on our Websites. We may use the data collected for optimizing marketing, refining advertising, and generally making advertising more effective. Google provides a complete privacy policy and instructions on opting out of Google Analytics here: http://www.google.com/intl/en/analytics/privacyoverview.html.
  
• Adobe Analytics – We may also use Adobe Analytics.  For further information on Adobe Analytics and to opt out, please click here: http://www.adobe.com/privacy/opt-out.html.

We may tie non-personal information with personal information in order to provide you with customized recommendations, to help authenticate you or other data or information that you may provide, to prevent fraud and to ensure that our Websites meet your needs. When we tie non-personal information with personal information, it is considered “personal information” for the purposes of this Privacy Statement.

Why We Collect Information About You

We collect information about you primarily to provide services through the Websites, but also for other purposes that include but are not limited to:

• Customize our communications with you and provide personalized content, offers, and advertising, including on our Websites, based on information collected through tracking tools.
  
• Administrative purposes, such as to assist you with registration on our Websites and contact list or to respond to inquiries from you or notify you about information we believe may be useful to you.
  
• Administer offers, promotions and surveys.
  
• Communicate with you about industry-related issues.
  
• Operate, evaluate, and improve our business (including developing new products, managing communications, determining the effectiveness of our sales, marketing and advertising, performing accounting, auditing, billing, reconciliation and collection activities, and analyzing and enhancing our products and branded websites).
  
• Perform data analyses and other processing (including market and consumer research, trend analysis, and financial analysis).
  
• Protect against, and identify, fraud and other criminal activity or to exercise our rights or defend legal claims.
  
• Comply with applicable legal or regulatory obligations, including but not limited to, use in connection with legal claims, compliance, and regulatory or investigative purposes.
  
• For other legitimate business purposes.

With Whom Do We Share Information About You?

• Our Affiliates.  We may share your information with JMFE’s affiliates, including other subsidiaries of JMFE.
  
• Partners & Other Third Parties. We may share your personal information with partner organizations and others with whom we work to provide our products and services. For example, if JMFE partners with a third-party for a joint service, we may share your information with that third party.
  
• Others Working for Us.  We may share your information with third parties that perform services on our behalf, including running and analyzing our Websites or sending communications for us.
  
• Other Third Parties, as Required by Law.  We may share your information with other third parties, such as law enforcement or other government entities: (1) if we believe there has been a violation of our website policies; (2) if we believe that someone may be causing injury to our rights or property, other users, or anyone else; (3) to respond to judicial process or to provide information to law enforcement; or (4) as required by law.
  
• Corporate Restructure.  We may transfer information about you in the event of a liquidation, reorganization, merger, acquisition, consolidation, change of control, asset or stock acquisition/disposition or other corporate combination. Should such an event occur, we will use reasonable efforts to ensure the transferee uses your information in a manner consistent with this Privacy Statement.

We do not disclose personal information to third parties for their own direct marketing purposes.

How you can control your information

Opting-Out. You may opt out of receiving promotional or marketing material at any time by contacting chad.donaghue@jmfamily.com or by following the opt-out instructions included in the communications you receive. Your option not to receive promotional and marketing material will not preclude us from corresponding with you regarding your existing or past business relationships with us (e.g., use of our services or responses to requests for information to us either through use of our Websites or other means), and will not preclude us from accessing and viewing your information in the course of maintaining and improving our Websites and our services.

Your Browser Settings.  Your browser may give you the ability to control cookies or other tracking tools. The Help portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie and how to delete existing cookies.  Note that if you choose to disable cookies, it is possible that some of our Websites’ features may not function properly.  For more information on deleting or controlling cookies, visit www.allaboutcookies.org.

Do Not Track Requests. Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.

How We Protect Your Information

We do not sell, lease or rent information about you to non-affiliated third parties or entities for their marketing purposes.

We recognize the importance of maintaining the security of your information. We have implemented technical, administrative and physical security measures designed to protect your information from unauthorized access, disclosure, use and modification. Unfortunately, guaranteed security does not exist on the Internet or offline. We therefore cannot guarantee that your information will be free from unauthorized access by third parties. By using our Websites 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 our Websites. You understand and agree that we may post a notice on our Websites if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing via traditional postal mail.

Third-Party Websites

This Privacy Statement applies solely to information collected on our Websites. Our Websites may contain links to other Websites. We are not responsible for the privacy practices or the content of these other Websites.

International Data Transfers

If you choose to provide us with information, we may transfer that information to our affiliates or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union (“EU”) or other regions with laws governing data collection and use that may differ from US law, please note that you are transferring your personal information to the US and other jurisdictions which may not have the same data protection laws as the EU. You acknowledge you understand that by providing your personal information: (i) your personal information will be used for the uses identified above in accordance with this Privacy Statement; and (ii) your personal information may be transferred to the United States and other jurisdictions as indicated above, in accordance with applicable law.

Choice

We do not have a process for you to review and request changes to your nonpublic personal information that is collected through our Websites.

How You Can Access or Correct Your Information

We do not have a process for you to view, update or correct your information.

Personal Information We May Receive from Third-Party Social Networking Websites

If you choose to access or use third-party social networking services (such as Facebook, Twitter, or Yelp), we may receive personal information about you that you have already made available to those services, including information about your contacts on those services.  JMFE will not sell such information or use the information in a manner that is inconsistent with this Privacy Statement. Your decision to use a social networking site to interact with us will always be voluntary.

User-generated Content and Public Profile Features

JMFE Websites may contain interactive areas where users might submit comments or other content (including information about the user that might be displayed in the user’s public profile within an online community) that may be posted on the Websites or otherwise published. Users who do this should be aware that when they voluntarily disclose Personally Identifiable Information (e.g., name, e-mail address, etc.) in content submitted for posting or publication, the information can be read and used by others. This may result in unsolicited messages from other posters or parties. We make no representations and undertake no obligations as to the security or use of information you voluntarily include when submitting content.

Former Customers’ Information

If you have an inactive or closed account(s) with us, we will continue to adhere to the practices described in this notice.

Children’s Privacy

Our Websites are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13.

Privacy Rights

Pursuant to California Civil Code Section 1798.83, JMFE confirms that it does not disclose any person’s Personally Identifiable Information to third parties for their own direct marketing purposes.

California “Do Not Track” Disclosures

We do not track your on-line activity across other websites, nor do we knowingly permit any third-parties to conduct online tracking of you while you are visiting our Websites.  Our Websites do use web analytics services, which use cookies to analyze use patterns and may collect information about your use of the Websites, including your IP address.

Application of United States Laws

Our Websites are based on computers located in the United States, however, your Personally Identifiable Information may be stored both inside and outside of the United States.  While data protection and privacy regulations may differ in different parts of the world, as explained above, we maintain safeguards that comply with state and federal regulations to guard your nonpublic personal information.

Changes to This Privacy Statement

This Privacy Statement may be updated periodically and will be posted on our Websites, indicating when it was last updated. If there are material changes to our Privacy Statement, we will post a prominent notice on our Websites and/or provide other notice as required by law. Use of our Websites following such changes constitutes your acceptance of the revised Privacy Statement then in effect.

Contact Us

If you have any questions about our privacy practices or this Privacy Statement, please contact us at:

JM Family Enterprises, Inc. 
100 Jim Moran Blvd.
Deerfield Beach, FL 33442
or email us at chad.donaghue@jmfamily.com