We know how important privacy is, so here is our policy for the whole world to see
Don Jagoda Associates, Inc. (“We”, “Us”) has created this policy in order to demonstrate our commitment to privacy. This policy discloses our information gathering and dissemination practices for this website, www.dja.com and for our company in serving our clients. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
Information We Collect and Use
Visitors to our web site and the Promotion web sites built on behalf of our clients have the option of giving us contact information and other personally identifiable information, such as their name and email address. This information is used by us to enter the visitor in a Promotion, provide information, assess the needs of a business to determine suitable products and select and contact potential winners and other site visitors via phone, fax, email and regular mail.
When we receive, collect and process consumers’ personally identifiable information on behalf of our clients when we administer their promotions, we may also require sensitive information, such as social security number or date of birth. Consumers provide this information in a variety of methods, depending on the particular promotion. We only use this personally identifiable information to operate the sweepstakes or other promotion for our client, in order to select winners, award prizes or for other purposes of the promotion. We do not use the information for any other purpose. We maintain the information only for so long as necessary to verify and conduct the promotion and to provide redundancy for our clients. We do not provide this information to any entity other than our client and others involved in the operation of the promotion. Our clients’ privacy policies govern the use of these data and they remain their property. Any exceptions to these procedures will be announced in the promotion for which the change is made.
It is our policy to retain client data, including personal data necessary for the selection, notification and awarding of prizes in promotions and any tax forms that are legally required to be completed for awarding those prizes, for only as long as legally required or as requested by the client, whichever is longer. No personal data is collected other than that required to select, notify and award a prize winner per applicable law. All physical documents are shredded and disposed of. All electronic data is deleted and removed from all electronic devices including backups on a regular basis. All requests from clients for data to be retained longer than legally required or transferred to them or another vendor must be made in writing and in advance.
We also collect certain information, not personally identifiable, on our website and in connection with administration of promotions. We may collect information about your computer configuration such as your browser type, operating system, or ISP domain name. We may collect information about the site you last visited prior to the Promotion or about your activity during your visit to the Promotion site. We may also offer social sign-on services that allow you to register for a promotion using a third-party social networking site such as Facebook, Instagram, Google or Twitter. By using these services you allow us to access the available information from your third-party social network profile such as your name, age, gender, location, email address and list of friends. This information may be used by us to administer the technical and operational aspects of the site, and may include using your IP address to help diagnose problems with our server. Your IP address may also be used to gather broad demographic information for aggregate use. This enables us to safeguard the promotion and diagnose problems in the operation of a promotion.
We do not support Do Not Track browser settings and do not participate in any Do Not Track frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.
Compliance with GDPR:
To those of you in the European Economic Area (EEA), and the United Kingdom (UK) we collect and process information about you only where we have legal bases for doing so under applicable regulations. We collect and use your information only when you give us consent to do so.
If you consented to use of information about you for a specific purpose, such as a Promotion entry, you have the right to change your mind at any time but this will not affect processing that has already taken place. You have the right to object to that use although this may mean no longer participating in a Promotion. If we are unable to manage your participation in a Promotion without the personal data provided (such as registration information), you will no longer be able to participate in the applicable Promotion.
We use data hosting service providers in the United States to host and store the information we collect, and we use various technical measures to secure your data.
We keep personal data and other information we collect about Promotion participants for as long as we need to in order to fulfill our services. After such time, we will delete the information or, if this is not possible, we will securely store your information and isolate it from further use until deletion is possible.
We act as a data processor on behalf of our clients. Each of our clients is the data controller for the data they collect in the applicable Promotion and is the sole owner of that data. Individuals have the right to access the personal data processed about them, subject to applicable law. Individuals may request to access their personal data processed by us by emailing us at firstname.lastname@example.org. If we collect your personal data on behalf of a client in connection with that client’s Promotion, your request should be directed to the client data controller. In most cases, we will direct your request to our client, the data controller. You have certain choices available to you when it comes to your information. Subject to applicable law, you may have some or all of the following rights available to you in respect of your personal data:
- to obtain a copy of your personal data together with information about how and on what basis that personal data is processed;
- to rectify inaccurate personal data (including the right to have incomplete personal data completed);
- to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);
- to restrict processing of your personal data under certain circumstances
- to port your data in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you;
- to withdraw your consent to our processing of your personal data (where that processing is based on your consent); and
- to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization.
In relation to these rights, you may contact us at email@example.com
If you contact us regarding personal data collected in connection with a client Promotion for which we are a data processor, we will attempt to refer your request to the relevant client, which is the sponsor of the Promotion and the data controller. We are not responsible for responding to your request on behalf of the data controller and your request will be directed to the client only. We will process such requests only upon instructions from the data controller that is sponsoring the Promotion.
If we are required to respond directly to your request, we may require proof of identity. We also reserve the right to charge a fee where permitted by law, especially if your request appears unfounded, excessive, or abusive. We will use reasonable efforts to respond to your request within all applicable timeframes.
Your California Privacy Rights (California Civil Code Section 1798.83)
California Consumer Privacy Act Privacy Statement (“CCPA Statement”)
This CCPA Statement is provided pursuant to the California Consumer Privacy Act (“CCPA”) and applies to California residents and supplements our overall Statement with additional disclosures and rights.
Your rights under CCPA
As of January 1 2020, California law permits residents of California to request certain details about how their personal information is shared with third-parties or affiliated companies for direct marketing purposes.
California residents may also take advantage of the following rights:
- You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
- You may request that we delete any personal information that we have collected from or about you. As described in more detail in our Statement, there are some reasons we will not be able to fully address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation. You can also access, update, and remove your information by visiting here.
- You may request to opt out of our sale of your personal information to third-parties for their direct marketing purposes. This means that, if you opt out, going forward, we will not share your information with such third-parties to use for their purposes unless you later direct us to do so. To effect the opt out, please click on the Do Not Sell My Personal Information link on our website footer or submit a request in writing to the contact information below.
To take advantage of your disclosure and deletion rights, please contact us via our dedicated privacy portal by clicking here. We may need to verify your identity to enable us to process your request. We value your privacy and will not discriminate in response to your exercise of privacy rights. We will respond to your request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.
For purposes of compliance with the CCPA, in addition to the further details as described in the Statement, we make the following disclosures:
- We collect the following categories of personal information: Identifiers/Contact Information, transactional information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above.
- We sell the following categories of personal information: Identifiers/Contact Information, Internet or other electronic network activity information, and inferences drawn from the above.
- We disclose the following categories of personal information for a business purpose: Identifiers/Contact Information, commercial information, Internet or other electronic network activity information, geolocation, visual and audio information, and inferences drawn from the above.
Your Access and Choices Regarding Your Data
Upon request you may view and have inaccuracies corrected in contact information or other personally identifiable information, by sending us an e-mail to: firstname.lastname@example.org with “Contact Correction” written in the subject line and the correct information written in the body of the email, or you may mail us your request to the address below. We will respond to your request to access within 30 days.
If you have provided us with contact information or other personally identifiable information and do not want to receive e-mail from us in the future and wish to delete such information, please let us know by sending an e-mail to email@example.com with “Remove from List” written in the subject line, or you may mail us your request to the address below.
When you provide personal information to us through our website, we will retain your information as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We abide by the Children’s Online Privacy Protection Act (“COPPA”). We will not knowingly allow anyone under 13 to provide to us, or to any of our clients on their behalf, any personally identifiable information.
Sharing your Information with others
We may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.
We may also disclose your personal information: as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; to any other third party with your prior consent to do so.
The security of your personal information and our Client’s information is important to us. When sensitive information (such as a social security number) is entered in our promotion and sweepstakes forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at: firstname.lastname@example.org
Other Privacy Information
Our Web site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Don Jagoda Associates, Inc.
100 Marcus Drive
Melville, NY 11747