Online Privacy Notice

Effective Date: October 13, 2020

Last Updated: November 2, 2023

I. Purpose

J.S. Held LLC, its affiliates, and related entities (hereinafter known as “J.S. Held”, “we”, “our”, or “us”) is committed to protecting your privacy and providing you with a secure experience as practically possible in the use of our website, mobile apps, and the provision of our diverse business services that we offer (“Services”), which can be found in more details at: https://jsheld.com/consulting-expertise.

This Online Privacy Notice (“Privacy Notice”) explains how we may collect, use, disclose, and protect your Personal Information (as defined in Section IV). This Privacy Notice also explains what to do if you do not want to receive marketing e-mails from us. If J.S. Held uses your Personal Information, you may exercise various rights depending on where you are located. See Section VI. for more detailed information.

Please read this Privacy Notice carefully. Each time you visit our Website, Mobile Apps (as defined in Section IV) or use our Services, you consent to the collection, use, storage, and sharing of your Personal Information unless you have previously opted-out, consistent with our then-current Privacy Notice.

II. Scope of this Privacy Notice

This Privacy Notice applies to Personal information which is collected and/or used by J.S. Held in its capacity as a Controller and as a Processor (as defined in Section IV). As a Processor, when we provide Services to our clients and handle Personal Information, we are only processing that information solely on the instruction of our clients, who ultimately are the Controllers of that Personal Information.

We also process Personal Information that has been collected by or provided to us through our Website, other Communications and Mobile Apps and Services that link to or post this Privacy Notice, as well as potential clients that we market to, recruitment applicants, attendees at J.S. Held conferences and related individuals.

BY USING OUR WEBSITE, MOBILE APPS, OR COMMUNICATIONS, AND WHEN YOU PURCHASE AND USE OUR SERVICES, YOU UNDERSTAND AND ACKNOWLEDGE THAT WE WILL COLLECT AND USE YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY NOTICE. If you have questions, you can always reach out to us by using any of the ways described in the Contact Us Section.

III. Changes to this Privacy Notice

We reserve the right to revise, amend, or modify this Privacy Notice at any time with or without prior notice and will post the updated version and its effective date at jsheld.com. All interactions with J.S. Held will be governed by this Privacy Notice. Please review the Privacy Notice periodically for updates.

IV. Definitions

Most capitalized terms are defined within this Privacy Notice, however, other important terms are included here.

  1. Communications” is any mode of interacting with you relating to J.S. Held communications, such as email, online or offline newsletters, and related materials, that reference this Privacy Notice.
  2. Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Information.
  3. Data Subject Rights Request” gives individuals the right to discover what data an organization is holding about them, why the organization is holding that data, and to who else their information is disclosed to.
  4. Mobile Apps” means downloadable applications accessed from mobile devices with respect to which this Privacy Notice is posted or linked.
  5. Personal Information,” recognizing that the definition of personal information varies significantly based on applicable law or standard, for purposes of this Privacy Notice, we define personal information as any information that identifies, relates to, describes, or is capable of being associated with, a particular individual. This may include information such as a unique personal identifier, name, alias, social security number, physical description, address, telephone number, e-mail address, passport number, driver’s license or state identification data, account information, insurance policy data, education, employment-related information, financial information, medical information, health insurance information, commercial information or other purchase or consumption data, biometric information, Internet Protocol address, online identifiers or other electronic network information activity, geolocation data, audio, electronic, visual, and inferences drawn from any of the information identified to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, and aptitudes.
  6. Processor” means a natural or legal person, public authority, agency, or other body which processes Personal Information on behalf of the Controller.
  7. Website” means web pages of the jsheld.com website, which is designated as a United States website or web pages, or any other website with respect to which this Privacy Notice is posted or linked.

V. Legal Requirements around Personal Information

a. Collection and purpose limitation

J.S. Held collects Personal Information only where necessary and uses it in line with its purpose for collection.

b. Data quality

To the best of our ability, J.S. Held strives to ensure that the Personal Information it processes is accurate, complete, timely and relevant to the purpose for which it is collected.

c. Data retention and destruction

J.S. Held maintains its records as required by applicable laws and regulations. Your Personal Information shall be retained to fulfill the purposes outlined in this Privacy Notice and destroyed in accordance with the Company’s policies governing data retention and in compliance with applicable laws and regulations.

d. Legal basis for processing personal information

J.S. Held shall establish a legitimate legal basis for the processing (collecting, using, sharing, etc.) of Personal Information. Where there are specific requirements for that legal basis, such as consent, we shall abide by those requirements where it is in the Company’s control.

e. Record of data processing

J.S. Held maintains its records as required by applicable laws and regulations, and where required, retains records of data processing activities.

f. Data transfers

J.S. Held is a United States limited liability corporation and may transfer certain Personal Information across geographical borders to other J.S. Held affiliates and related entities or to outside companies working with us or on our behalf. We may also store Personal Information in a jurisdiction other than where you are based, and such jurisdiction may not provide the same level of protection for your Personal Information as your home country. By providing your Personal Information to J.S. Held, you are consenting to this transfer and/or storage of your Personal Information across geographical borders. Each J.S. Held affiliate and related entity is required to safeguard Personal Information in accordance with its contractual obligations and data protection legislation applicable to its provision of Services. Your Personal Information will only be transferred if appropriate or suitable safeguards are in place.

g. Transparency and notice

Where required and where the Company obtains the Personal Information for its own purposes and not through a contractual agreement, the Company shall communicate transparently with individuals regarding the Company’s privacy practices by providing them with this Privacy Notice which is posted on the jsheld.com Website. Notice shall be provided at or before (or as soon as practical thereafter) the time Personal Information is collected, and when the Company changes its privacy practices and procedures that impact what notice shall be provided. Where applicable, this Privacy Notice shall be mobile-optimized for readability on mobile devices.

VI. Data Subject Rights Request

Under applicable laws and regulations, you may have various rights to your Personal Information such as the right to access, review, modify, obtain a copy, stop sharing, or, in certain instances, delete the Personal Information that J.S. Held has collected, used, or disclosed about you.

If you reside in a state or country that provides you with Data Subject Rights, you can submit a Data Subject Rights Request by completing this form or emailing us at [email protected]. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.

We may ask you for additional information to confirm your identity before disclosing any personal information to you. We reserve the right to charge a fee, where permitted by law, for instance, if your request is manifestly unfounded or excessive. 

If you are located in any of the locations listed below, please find additional state/country-specific privacy disclosures and more information further below on how you can exercise your Data Subject Rights Request.

State/Country

VII. Data Protection Officer

The Company has appointed an internal data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions or concerns about J.S. Held’s personal data policies and practices or would like to exercise your privacy rights, please direct your inquiry to the DPO at [email protected].

You have the right to make a complaint at any time to the applicable supervisory authority for data protection issues. We would, however, appreciate the chance to handle your concerns before you do so, so please contact us at [email protected] in the first instance if you have any comments or concerns.

VIII. Personal Information We Collect About You

The types of Personal Information we collect about you will depend on your relationship with J.S. Held. For example, in many cases, we may collect Personal Information from our business clients during an engagement to provide Services to our clients, and our collection and use of Personal Information is governed by our contractual obligation with that third party. In other cases, we may collect Personal Information directly from former, current, and/or prospective clients. The following is a summary of the types of Personal Information we may collect from you:

1. Website and Mobile App Users

We collect Identifiers such as your name, address, e-mail address, telephone number and any other Personal Information you voluntarily provide in the “questions” box when you submit an inquiry through the "Contact Us" link on our Website. J.S. Held may also collect Personal Information using cookies or similar technology to ensure the effective operation of our Website or Mobile App. See Section XIV. Information about your Website and Mobile Apps Activity for more detailed information.

We may also collect Personal Information if you register for the Website using a third-party social media account such as LinkedIn, Facebook, or Twitter (such accounts are collectively referred to as a “Social Media Account”). The information we collect may depend on the privacy settings you have with the Social Media Account, so please review the privacy statement or notice of the applicable Social Media Account.

2. Former, Current, and Prospective Clients

If you submit an inquiry to J.S. Held about our Services, in any form, then we will process Identifiers such as your name, job title, telephone number, and e-mail address in order to respond to your inquiry.

If you attend a J.S. Held event or webinar, or if you meet with a J.S. Held employee at an industry event, then J.S. Held may collect Identifiers, such as your business contact information in order to facilitate your participation in that event or webinar, and for the management of our relationship with you as an actual or prospective client.

Considering the applicable marketing laws, we also process Personal Information about former, current and prospective clients in order to send you newsletters, promotional material, and other Communications as well as invite you to events and to arrange and administer those events.

3. Performing Services for Our Clients

As discussed above, many of our Services involve the processing of Personal Information that are dependent on the type of Services we are conducting for our clients (see a-h below for possible types of Personal Information we may collect). In most cases, Personal Information is provided to us in strict confidence and is subject to restrictive covenants on its use, disclosure, and retention.

4. Other Users

If you apply for a position with J.S. Held, we will need to collect Identifiers such as your name, address, e-mail address, telephone number, and other Personal Information in order to consider your application, continue with the interview process and assess your qualifications for the position.

Depending on your relationship with J.S. Held, we may collect the following categories of Personal Information:

  1. Identifiers, which may include name, alias, address, telephone number, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account information, financial and insurance information, medical information, physical characteristics or description, social security number, driver's license number, passport number, or other similar identifiers.
  2. Protected Classification Characteristics, which may include age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, sexual orientation), veteran or military status, union membership, genetic information (including familial genetic information) or other classifications protected by law.
  3. Commercial Information, which may include records of property, Services purchased, obtained, or considered, or other purchasing or consuming histories, or tendencies.
  4. Internet or Other Similar Network Activity, which may include browser or domain data, Internet Protocol address, navigation history, and other information on a consumer's interaction with a Website, Mobile Apps, or advertisement.
  5. Geolocation Data, which may include GPS data, locational information based upon your IP address, and/or other similar locational data.
  6. Sensory Data, which may include records of calls to or from customer service, and/or video surveillance information, or similar information.
  7. Professional or Employment-Related Information, which may include information regarding your current and previous employers, job title and responsibilities or employment history.
  8. Inferences Drawn from other Personal Information, which may include profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may collect Personal Information as listed above from the following sources:

  • Directly from our clients, customers, and prospective clients and customers or their authorized agents, including via applications and forms, Communications and interactions with us, and through our Website and Mobile Apps;
  • Directly and indirectly from our affiliates and related entities;
  • Directly from job applicants;
  • Directly and indirectly from activity on our Website, Mobile Apps, and our Communications with you; and
  • From third parties that interact with us in connection with the Services we or the third parties perform.

We will not collect additional categories of Personal Information without first providing you with notice.

IX. Your Opt-Out Choices

If you register for our Website, Mobile Apps, or Communications, you will be given the opportunity to choose not to receive our promotional messages. If you would like to unsubscribe from receiving these promotions, please send an e-mail to [email protected]. You may also click on the UNSUBSCRIBE link contained in any promotional e-mails that may be sent to you by J.S. Held. If you would like to opt-out of receiving tailored online advertisements from us, please send us an e-mail at [email protected].

X. Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the Personal Information to J.S. Held, such as to create your account, process your transaction or respond to your inquiry.
  • To communicate with you, including via e-mail, text message, push notification, social media, and/or telephone calls. We may retain your e-mail, e-mail address, and our responses to you. This Personal Information is used to answer your follow-up questions and measure how effectively we address your concerns.
  • To assist with calls made to our representatives or visits made to our office locations. We may collect and combine Personal Information from other sources with Personal Information that you provide online.
  • To personalize your experience and to deliver custom content and Service offerings relevant to your interests, including targeted offers and ads through our Website, Mobile Apps, Communications, third-party sites, or on other devices you may use. We may ask you to voluntarily provide us with information about your interests, demographics, experience with our Services, and contact preferences to help customize offerings to you.
  • If you send us a resume or curriculum vitae (“CV”) to apply online for a position with J.S. Held, we will use the Personal Information that you provide to match you with available J.S. Held job opportunities.
  • To recognize you and remember your information or location when you return to our Website, Mobile Apps and Services.
  • To assist with the operations of Mobile Apps. We may share your usage and Personal Information with mobile carriers, platform providers, and other similar third parties in connection with the operation of the Mobile App.
  • To release information to any law enforcement or other government agency, as required by applicable law or regulation, to enforce the terms of agreements or protect rights, property, or safety. Under such circumstances, we may be prohibited from providing you with notice of such disclosure, and we reserve the right not to provide you with such notice.

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without first providing you with notice.

XI. Sharing Personal Information

We do not share Personal Information with unaffiliated third parties, except as stated in this Privacy Notice, including as necessary for our legitimate professional and business needs, to carry out your requests, to market our Services, as required or permitted by law, or otherwise with your consent.

In some instances, we may share Personal Information about you with various third-party service providers and vendors working on our behalf. These third parties include providers of website hosting, infrastructure provisioning, IT services, customer service, e-mail delivery services, marketing and advertising services, and other similar service providers. We may share your usage and Personal Information with mobile carriers, platform providers, and other similar entities in connection with the operation of the Website, Mobile Apps, or Communications.

Each third party is required to safeguard Personal Information in accordance with its contractual obligations and data protection legislation applicable to its provision of services.

We may share your Personal Information with subsidiaries or affiliates of J.S. Held, so that they may send you information about special interests or Services that may be of interest to you based on your purchase history, activity on our Website, Mobile Apps, Communications, and other information that you have given us.

We may share your Personal Information with law enforcement and regulatory authorities or other third parties as required or permitted by law, including for the purpose of: 1) responding to a subpoena, court order, or other legal processes; 2) defending, protecting, or enforcing our rights; 3) assisting in the event of an emergency; and 4) complying with applicable law or regulation.

If we sell, transfer, or otherwise share some or all our assets in connection with a merger, reorganization, liquidation, dissolution, or sale of assets, we may transfer your Personal Information without your consent.

We may share some aggregated, anonymized, and statistical non-Personal Information with third parties to better understand how our Website and Mobile Apps are used and to improve user experience.

XII. Sale of information

In the previous 12 months, we have not sold Personal Information as most people would typically understand that term. However, we do work with certain networks, social media companies, and other third-party businesses to collect and disclose your Personal Information directly from your browser or device through cookies and related technologies when you visit or interact with our Website, Mobile Apps and otherwise engage with us online. This information is used to provide and inform targeted marketing materials, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. See Section XIV. Information about your Website and Mobile Apps Activity for more detailed information about how third parties use cookies and related technologies to collect information automatically on our Website, Mobile Apps, and other online services, and the choices you may have in relation to those practices.

Depending on the jurisdiction in which you are located, you may have the right to request that we not disclose your personal information we hold. To exercise this right, you may submit a request by emailing us at [email protected] or visiting the Do Not Sell My Personal Information link on our website, and US residents may call (877) 871-4113.

XIII. Safeguarding Your Personal Information

J.S. Held recognizes the importance of protecting your Personal Information and we endeavor to maintain reasonable security measures to protect against unauthorized disclosure or access. J.S. Held requires its service providers and third parties to have security policies and procedures in place to help protect Personal Information from unauthorized loss, misuse, alteration, or destruction. However, despite J.S. Held’s efforts, no method of data transmission or storage is 100% secure, so we cannot guarantee against all threats.

a. Links to Other Sites

The jsheld.com Website, Mobile Apps, and Communications may provide links to other websites, mobile applications, or social media pages operated by other third parties. If you click through to another website, mobile application, or webpage, your activity will be subject to the privacy notice of that website, mobile application, or webpage, and not to the J.S. Held Privacy Notice. We recommend that you review the privacy notices of those websites, mobile applications, or webpages before you use them.

b. Use of the J.S. Held Website and Mobile Apps by a Child Under Age 13

The content posted on the J.S. Held Website and Mobile Apps is intended for use by adults. J.S. Held does not knowingly collect information from children under the age of 13. If a child provides us with any Personal Information, the parent or guardian should notify J.S. Held by sending an e-mail to [email protected]. Upon receipt of the e-mail, we will delete the child’s information and will remove it from any promotional contact list and database.

XIV. Information about your Website and Mobile Apps Activity

If you use our Website or Mobile Apps, we may use cookies and other technologies to collect anonymous information, such as your browser and domain data, navigation history, and other information. We may also use anonymized information for advertising purposes and general analytics. We may use information about your location primarily to locate our nearest office location and send you location-based notifications. We also may use information about your location for the same purposes we use your Personal Information, including to provide you with, and improve, relevant marketing or offers for Services from us.

You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. Check your specific browser’s website to learn how to adjust your cookie settings. Please note that if you opt-out of tailored advertising, you will continue to receive general ads. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. You must perform the opt-out on each browser or device you use. These opt-out choices may not affect online advertising that is not cookie-based. Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you may need to opt-out again. Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our Services. In addition, third parties may still use cookies to collect information about your use of our Services, including for analytics and fraud prevention as well as any other non-advertising purpose.

You may be able to limit the use of location data for advertising purposes by adjusting your location services settings on your mobile device. You can also stop sharing your location information on your mobile device through the applicable Mobile App by turning off location services or by uninstalling the Mobile App.

You may also be able to limit mobile interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

a. Information that Third-Parties May Collect About Your Activity on the Website and Mobile Apps

Third-party services, such as Facebook tracking pixels, Google Analytics, or other data aggregators may collect your information on J.S. Held Website and Mobile Apps. They do not provide information back to J.S. Held that links user website activity data to specific individuals. Some of these services may be able to link the user’s activity on the J.S. Held Website and Mobile Apps with other data and target a message to a specific user when the user is on another web or social media site.

In addition to the above, we have implemented on our websites with certain Google Analytics features that support display advertising, including re-targeting. Visitors to our Website may opt-out of certain types of Google Analytics tracking, customize the Google display network ads by using the Google ad preferences manager, and learn more about how Google serves ads by viewing Google’s Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.

If you have questions about an ad or other targeted content that you receive, or how third-party services use your data, you should contact the third-party services directly.

XV. Contact Us

If you have any questions regarding this Privacy Notice, the ways in which we may collect and use your Personal Information, how to update or correct any outdated or inaccurate information, your choices and rights regarding such use, or wish to exercise your Data Subject Rights Request with respect to your Personal Information, please contact us at [email protected], visit the Do Not Sell My Personal Information link on our website, or call (877) 871-4113.

CALIFORNIA-BASED INDIVIDUALS ONLY – Your Rights and Choices

This California Privacy Notice (the “CA Disclosures”) supplements the information contained in the Privacy Notice and applies solely to individual residents of the State of California ("you"). These CA Disclosures describe how individuals in the State of California can exercise their Data Subject Rights Request pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) (as amended by the California Privacy Rights Act of 2020 (“CPRA”). Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in the Privacy Notice or as otherwise defined in the CCPA.

a. Notice at Collection

At or before the time of collection, you have a right to receive notice of our practices, including the categories of Personal Information and Sensitive Personal Information (as defined in the CCPA) to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Privacy Notice by clicking on the above links.

b. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you regarding our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your Data Subject Rights Request, we will disclose to you:

  • The categories of Personal Information we collected about you;
  • The categories of sources for the Personal Information we collected about you;
  • Our business or commercial purpose for collecting or selling that Personal Information;
  • The categories of third parties with whom we share that Personal Information;
  • The specific pieces of Personal Information we collected about you (also called a data portability request); and
  • If we sold or disclosed your Personal Information for a business purpose.

Please note that the above is provided in further detail in this Privacy Notice.

c. Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained in our records, subject to certain exceptions. Once we receive and confirm your Data Subject Rights Request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

d. Correction Request Rights

You have the right to request that we correct inaccurate Personal Information we may hold, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. Depending on the circumstances, we may require you to provide documentation supporting your request to correct your Personal Information.

e. Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to limit our use or disclosure of your Sensitive Personal Information for any purpose other than to provide the service you request, or as otherwise permitted by law. Please note, J.S. Held does not use or disclose Sensitive Personal Information for any purposes other than those necessary to provide the relevant services or as permitted by the CCPA, and J.S. Held does not sell or share your Sensitive Personal Information and has not done so in the preceding twelve (12) months.

f. Exercising Your CCPA Rights

To exercise the right to request access, data portability, correction, or deletion as described above, please submit a Data Subject Rights Request to us by either sending an email to [email protected]; or calling us at (877) 871-4113. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a Data Subject Rights Request related to your Personal Information. You may also make a Data Subject Rights Request on behalf of your minor child. You may only make a Data Subject Rights Request for access or data portability twice within a 12-month period. We will need to verify your identity before processing your request, which may require us to request additional Personal Information from you. We will only use Personal Information provided in connection with a Data Subject Rights Request to review and comply with the request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

g. Exercising Your Right to Opt-Out of Personal Information Sales

J.S. Held does not sell your Sensitive Personal Information and has not done so in the preceding twelve (12) months. To inquire about your rights including the Right to Opt-Out of Personal Information Sales, you may submit a request by calling us at (877) 871-4113 or emailing us at [email protected].

h. Response Timing

We strive to respond to a Data Subject Rights Request within 45 days of its receipt. If we require additional time, we will inform you of the reason and extension period in writing. Written responses will be provided based upon the information you provide to us. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity, if the rights of another individual might be violated or as otherwise permitted by law. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

i. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by California law, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

j. Use of the J.S. Held Website and Mobile Apps by a Child Under Age 16

The content posted on the J.S. Held Website and Mobile Apps is intended for use by adults. J.S. Held does not knowingly collect information from children under the age of 16. If a parent or guardian becomes aware that a child provides us with any Personal Information, the parent or guardian should notify J.S. Held by sending an e-mail to [email protected]. Upon receipt of the e-mail, we will delete the child’s information, and will remove it from any promotional contact list and database.

k. California Privacy Rights Reporting

J.S. Held has compiled the following data regarding individuals who made personal information requests under the CCPA of otherwise from January 1 – December 31, 2022. In accordance with CCPA Regulation, this information is being made available in this Privacy Notice and posted on the J.S. Held website.

Requests Received

Requests Complied With

Requests Denied

Requests to Know

0

0

0

Requests to Delete

0

0

0

Requests to Opt-Out

0

0

0


Data reflects all individual rights requests received by J.S. Held from US individuals between Jan. 1 – Dec. 31, 2022.

If you have any questions regarding this section of this Privacy Notice, please contact us at [email protected] or call (877) 871-4113. 


VIRGINIA-BASED INDIVIDUALS ONLY – Your Rights and Choices

This Virginia Privacy Notice (the “VA Disclosures”) supplements the information contained in the Privacy Notice and applies solely to individual residents of the State of Virginia ("you"). These VA Disclosures describe how individuals in the State of Virginia can exercise their Data Subject Rights Request pursuant to the Virginia Consumer Data Protection Act (CDPA). Unless otherwise expressly stated, all terms in these VA Disclosures have the same meaning as defined in the Privacy Notice or as otherwise defined in the CDPA.

a. Access to Specific Information and Data Portability Rights

You have the right to obtain confirmation as to whether or not Personal Information concerning you is processed, and, where that is the case, you have the right to request and get access to that Personal Information from us. We shall provide you with access to the Personal Information we hold in a commonly accepted format that is reasonably acceptable to you and provided in a timely manner.

b. Withdrawal of Consent and Right to Object

We shall provide you with a choice about the processing of your Personal Information and seek consent. In certain cases, you have the right to object to processing of your Personal Information. You also have the right to object to further processing of your Personal Information in so far as such data have been collected for direct marketing purposes.

c. Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained in our records, subject to certain exceptions. Once we receive and confirm your Data Subject Rights Request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

d. Exercising Your CDPA Rights

To exercise the access, data portability, and deletion rights described above, please submit a Data Subject Rights Request to us by either visiting here; or calling us at (877) 871-4113. Only you or a person registered with the Virginia Secretary of State that you authorize to act on your behalf, may make a Data Subject Rights Request related to your Personal Information. You may also make a Data Subject Rights Request on behalf of your minor child. You may only make a Data Subject Rights Request for access or data portability twice within a 12-month period. We will need to verify your identity before processing your request, which may require us to request additional Personal Information from you. We will only use Personal Information provided in connection with a Data Subject Rights Request to review and comply with the request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

e. Exercising Your Right to Opt-Out of Personal Information Sales

J.S. Held does not sell your Sensitive Personal Information and has not done so in the preceding twelve (12) months. To inquire about your rights including the Right to Opt-Out of Personal Information Sales, you may submit a request by emailing us at [email protected].

f. Response Timing and Appeal Process

We strive to respond to a Data Subject Rights Request within 45 days of its receipt. If we require additional time, we will inform you of the reason and extension period in writing. Written responses will be provided based upon the information you provide to us. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity, if the rights of another individual might be violated or as otherwise permitted by law. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request. You also have the right to request an appeal if we are unable to comply with your request. We strive to response to your appeal within 60 days of its receipt, including a written explanation of the reasons for the decisions. If the appeal is denied, you have the right to submit a compliant with the Virginia Attorney General’s office.

g. Non-Discrimination

We will not discriminate against you for exercising any of your CDPA rights. Unless permitted by Virginia law, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

If you have any questions regarding this section of this Privacy Notice, please contact us at [email protected] or call (877) 871-4113. 


EUROPEAN UNION BASED INDIVIDUALS ONLY – Your Rights and Choices

This European Union Privacy Notice (the “EU Disclosures”) supplements the information contained in the Privacy Notice and applies solely to individual residents of the European Union ("you"). These EU Disclosures describe how individuals in the European Union can exercise their Data Subject Rights Request pursuant to the General Data Protection Regulation (GDPR). Unless otherwise expressly stated, all terms in these EU Disclosures have the same meaning as defined in the Privacy Notice or as otherwise defined in the GDPR.

a. Access to Specific Information and Data Portability Rights

You have the right to obtain confirmation as to whether or not Personal Information concerning you is processed, and, where that is the case, you have the right to request and get access to that Personal Information from us. We shall provide you with access to the Personal Information we hold in a commonly accepted format that is reasonably acceptable to you and provided in a timely manner.

b. Rights to Correction, Amendment, and Deletion

You have the right to have your Personal Information corrected, amended, and/or deleted by us, recognizing that there may be legal or technical reasons that prohibits or restricts honoring such request. You also have the right to provide us additional Personal Information to complete any incomplete Personal Information. We shall provide you with confirmation of the completion of such request where granted. Where there is a legitimate reason not to do so, we shall explain the reason for denial to you.

c. Rights for Choice, Consent, and Right to Object

We shall provide you with a choice about the processing of your Personal Information and seek consent. In certain cases, you have the right to object to processing of your Personal Information, including with regards to profiling and automated processing. You also have the right to object to further processing of your Personal Information in so far as such data have been collected for direct marketing purposes.

d. Other Rights

We intend to honor the rights granted to individuals under applicable law or other binding requirements. Any rights not otherwise listed above shall be granted where required. When considering such requests, we shall consider legal, contractual, and technical limitations.

e. Communications to/from Third-Parties

Where we have shared Personal Information to third-parties and where the Personal Information is reasonably feasible, we shall notify applicable third-parties of your request. We shall also require third-parties to notify us of your request to exercise your rights and the intent to abide by any requests.

f. Exercising Your GDPR Rights

To exercise any of your rights as described above, please submit a Data Subject Rights Request, which includes which right you would like to exercise by contacting us at [email protected].Only you or a person you authorize to act on your behalf, may make a Data Subject Rights Request related to your Personal Information. You may also make a Data Subject Rights Request on behalf of your minor child. The Data Subject Rights Request must provide enough information that allows us to reasonably verify your identity and describe your request with enough detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

g. Response Timing

We strive to respond to a Data Subject Rights Request within 30 days of its receipt. If we require additional time, we will inform you of the reason and extension period in writing. Written responses will be provided based upon the information you provide to us. We use any information you give us in your request only to fulfill the request and delete it within 12 months.

If you have any questions regarding this section of the Privacy Notice, please contact us at [email protected] or calling us at 1 (516) 621-2900.

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