Jet The World Privacy Policy

Effective December 3, 2020

Jet The World is a private aviation charter broker, travel concierge, and aircraft acquisition and management consultant.  We focus on luxury, privacy, and personal service.

This Privacy Policy explains how JTW Jets LLC, which does business under the trade name Jet The World, and our affiliates (“JTW”, “we”, or “us”) protect your personal information and respect your privacy.  This policy is applicable to our website https://www.jettheworld.com/ (our “Website”), communications between us by email, social media, text/phone, or other electronic means, and in conjunction with our provision of private aviation services to you (together with the “Services”).

By using or accessing our Website, interacting with us by other electronic means, or communicating with us regarding the Services, you acknowledge your acceptance of the policies and practices outlined in this Privacy Policy.  Your use of or interaction with the Services is your consent to JTW to collect, use, and share your information in the manner outlined in this Privacy Policy.  In addition, your use of the Website is subject to any Terms of Use posted on our Website from time to time.  Any agreement between us for the provision of private aviation services is subject to the contract(s) entered into for that purpose and does not replace or alter our respective rights and obligations under this Privacy Policy, notwithstanding any integration clause.   Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

Where we need to collect Personal Data, defined below, by law or under the Terms of Use or another agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you, for example allowing you to utilize the Services including the Website.

Contact Information

You may contact us at any time with questions and comments about our collection and use of Personal Data and your rights and choices regarding Personal Data by email or post at:

Email Address              info@jettheworld.com

 

Postal Address              Jet The World

                                        Attn: Jet The World Privacy

                                        30 Wall Street, 8^th Floor

                                        New York, NY 10005

 

Where this Privacy Policy directs or allows you to email us, you may do so at the email address above and your inquiry will be forwarded to the relevant Data Protection Officer, Data Privacy Officer, or other appropriate personnel based on the nature of your inquiry and your location.

What this Privacy Policy Covers  

This Privacy Policy covers how we treat Personal Data that we gather when you access or use the Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we do not own or control or people we do not manage.

Sources of Personal Data

We collect Personal Data about you from you when (i) you provide such information directly to us including when you submit a contact form/quote request, send us an email, communicate with us through social media, or otherwise provide information to us such as by telephone or text, and (ii) when Personal Data about you is automatically collected in connection with your use of the Website.  When you purchase products or services from us we require billing and payment information and certain additional Personal Data of the types defined and explained below.

We also collect Personal Data about you from third parties (“Third Parties”). Third Parties that share your Personal Data with us may include:

• Service providers. We use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
• Social Networking Services connected to the Services. If you interact with us through a Social Networking Service or other third-party site or service, some content and/or information from those third-party services or accounts may be transmitted to us in accordance with the respective third-parties' own privacy policy and your agreements with those third-parties.
• Advertising partners. We may receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our Website, advertisements, or other communications.

Categories of Personal Data We Collect

The following chart details the categories of Personal Data that we collect and have collected over the past twelve (12) months. Throughout this Privacy Policy, we will refer back to the categories of Personal Data listed in this chart (for example, Category A. “Personal identifiers”).

 

	Category of Personal Data	Personal Data Collected	Source of this Personal Data?
A.	Personal identifiers	Real name, usernames or similar identifiers from other services, phone numbers, IP Address and Device ID when connected to the Internet	You/Third Parties
B.	Contact information	Home and/or business address, email address, and telephone numbers	You/Third Parties
C.	Profile and usage information	Browsing history, survey responses, information about how you use the Website, and your preferences including your communications and marketing preferences in conjunction with mailing list services	You/Third Parties
D.	Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))	bank account, routing number, credit card or debit card number, driver license, passport or other government identification information	You/Third Parties
E.	Transaction data	Payment details proposed and completed itineraries, services you have utilized from JTW	You/Third Parties
F.	Protected classification characteristics under state or federal law	Age, race, national origin, citizenship, sex, marital status	You/Third Parties
G.	Internet or other similar network activity information	Browsing, search, interaction history within the Website, IP Address IP and Device ID when connected to the Internet, URLs from websites you visit before and after using the Website, software and hardware attributes, IDFA and/or Advertising IDs, browser type and version	You
H.	Geolocation data	Physical location	You/Third Parties
I.	Sensory data	Audio and visual, including video conferencing/messaging conversations which you appear in as you interact with us in conjunction with our provision of the Services	You/Third Parties
J.	Business Information	Busines email, business entity filings, corporate affiliations, business associates, business phone number, and similar data	You/Third Parties
K.	Professional or employment-related information	Current and past job history if users choose to provide or we obtain from publicly available sources for customer verification or advertising purposes	You/Third Parties
L.	Age or date of birth	Age, date of birth	You/Third Parties
M.	Special categories of data under the EU General Data Protection Regulation	Race, national origin	You / Third Parties

 

Information Collected Automatically

Logs 

We may track the data you see when using the Website and how you interact with our Website by automatically collecting certain information such as “Internet or other similar network activity information”. To obtain such information, we may use web logs or applications that recognize your device and gather information about its online activity. We treat this information as Personal Data if we combine it with or link it to any of your information that otherwise is categorized as Personal Data. Otherwise, it is used in aggregate form only.

Cookies

The Website and emails we send you may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use the Website, to analyze trends, learn about our user base and operate and improve the Website.  A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information. For example, it allows an email sender to determine whether a user has opened a particular email.  Generally, Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Website. We may also supplement the information we collect from you with information received from third-parties, including third-parties that have placed their own Cookies on your device(s). We use or may use the following types of cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested or to make the Website readable and accessible to you. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies may be used to record your choices and settings, personalize content for you, and recognize you when you return to the Website.
• Performance/Analytical Cookies. Performance/Analytical Cookies are used to help us understand how visitors use the Website by collecting information about the number of visitors to the Website and users of the Website, what pages are viewed, and how long visitors are viewing pages or features of the Website. These types of Cookies help measure the performance of advertising campaigns and our content. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to our Website is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Website functionalities may not work.  Because of our use of Cookies, the Website may not support “Do Not Track” requests sent from your browser, which means that we may collect information about your online activity both while you are using our Website and after you leave our Website.

How you manage your cookie settings, including deletion, may differ per browser. Please use the “Help” function in your browser and look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/. If you want to disable cookies from specific parties, you can do so via www.youronlinechoices.com

We keep Personal Data contained in your cookies and obtained through the other tracking technologies confidential.  We do not set any cookies outside of our Website domain.  We also may partner with certain third parties to collect, analyze, and use some of the Personal Data described in this section.  For example, we may allow third parties to set cookies or use web beacons on the Website or in email communications from us. This information may be used for a variety of purposes, including analytics and online behavioral advertising.

Local storage

We may also collect and store information (including Personal Data) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

How We Use Your Personal Data

We process Personal Data to operate, improve, and understand the use of the Website and in conjunction with any agreements or contemplated agreements to provide you with private aviation services. We use Personal Data for the following purposes:

• To meet or fulfill the reason you provided the information to us;
• To communicate with you about us and the Services, including announcements, updates, offers, confirmations, security alerts, support, and administrative messages, and other communications necessary to facilitate your use of and our operation of the Services;
• To provide support and assistance for the Website and in relation to the Services;
• To personalize website content and communications based on your preferences, including targeted offers and ads served through the Services;
• To process orders or other transactions;
• To respond to user inquiries and fulfill user requests including opt-outs, data requests, deletions, and other interactions described in this Privacy Policy;
• To improve and develop the Services, including testing, research, analysis, and product development;
• To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security, and integrity of the Services;
• To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use and any other agreements with you;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• For any other purposes for which the information was collected as indicated above; and
• For any other business, purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you have provided us the means to do so. For example, if you have given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve the Services. If you do not want to receive communications from us, please indicate your preference by emailing us or utilizing the unsubscribe/opt-out links in our communications.

How We Share Your Personal Data

We disclose your Personal Data only for business purposes.  We may disclose your Personal Data to service providers and other parties for the following business purposes:

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use of Personal Data in connection with the Services that is not used by another party to build a consumer profile or otherwise alter your experience outside the current interaction;
• Performing services on our behalf or in connection with the Services, including maintaining or servicing accounts, providing customer service, providing relevant recommendations and personalized user experience, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control;
• Social media services, ad networks, and media services, accounts, and platforms, if you intentionally interact with them through your use of the Services;
• Third-party business partners who you access through the Services; and
• Other parties authorized by you.

We may disclose your Personal Data to the following categories of service providers and other parties:

• Aircraft operators, fixed based operators, catering and transportation providers, customs and government security officials, and other third-parties and vendors to whom we must provide your Personal Data to fulfill our obligations to you for the provision of private aviation services;
• Payment processors;
• Companies who send emails on our behalf;
• Ad networks and media services;
• Social media services;
• Security and fraud prevention consultants;
• Hosting and other technology and communications providers;
• Internal and external auditors;
• Analytics providers;
• Third-party business partners who you access through the Services;
• Charter management, customer records management, and acquisition/ownership/management software providers;
• Other parties authorized by you; and
• Staff augmentation, our affiliates, and contract personnel who are subject to our obligations under this Privacy Policy.

We may also disclose your Personal Data to parties who acquire your Personal Data through an acquisition or other change of control of our company, including a change of control of any subsidiary or affiliate. Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business, in whole or in part.

Over the past twelve months, we have disclosed the following categories of your Personal Data to service providers or other parties for the business purposes listed above, or may do so in the future:

• A. Personal identifiers
• B. Contact information
• C. Profile and usage information
• D. Customer records identified by state law
• E. Transaction data
• F. Protected classification characteristics under state or federal law
• G. Internet or other similar network activity information
• H. Geolocation data
• I. Sensory data
• J. Business Information
• K. Professional or employment-related information
• L. Age or date of birth
• M. Special categories of data under the EU General Data Protection Regulation

JTW has not and will not sell your Personal Data.

We may also disclose your Personal Data if required to do so by law or when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders.  We may also disclose your Personal Data when we believe that disclosure is necessary to protect our rights or the rights, property, or safety of others, to enforce or apply this Privacy Policy, our Terms of Use or our other policies or agreements.

We may also share aggregated data such as statistical or demographic data for any purpose.  Aggregated data could be derived from your Personal Data but is not considered Personal Data under applicable law as it will not directly or indirectly reveal your identity or Personal Data.  We do not link this aggregate user data with Personal Data.  Our Privacy Policy does not restrict or limit our collection and use of aggregated data.

No Personal Data of Children – Except as Required for Travel

By using the Services, you represent that you are at least 18 or that you are the parent or guardian of a minor utilizing the Services and consent to your dependent minor’s use of the Services.  As indicated in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 18.  If you are a child under 18 years of age, please do not attempt to use our Website or Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided us Personal Data, please contact us.

Notwithstanding the foregoing, certain Personal Data of children is required in order for us to facilitate the provision of travel services contracted for between JTW and our customers.  This information consists of the identifying information on the child’s passport and/or birth certificate, drivers license or state identification, and guardianship information.  It is collected only from adult users of the Services that are the child’s guardian or do so with explicit consent from the child’s guardian.  It is utilized strictly to comply with governmental regulations and operator’s policies for the safe and legal operation of the travel services.  It is not integrated with other Personal Data and is used strictly as required for the provision of travel services where the subject child is to be a passenger/guest and only retained as necessary for security and compliance requirements.  It is not used for advertising purposes or to build a customer profile for the child.  If you have any questions or concerns about the distinction between our limited use of your child’s Personal Data and our general use of Personal Data, please contact us at the email or postal address provided at the outset of this policy.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanisms; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss, or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Services. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Telephone Consumer Protection Act

By providing us with your wireless number by email or a contact form submission, you confirm that you want us to send you information regarding our services that we think may be of interest to you, which may include us using automated dialing technology to text you at the wireless number you provided, you agree to receive communications from us, and represent and warrant that each person for whom you provide a wireless phone number has consented to receive these communications. You agree to indemnify and hold harmless JTW, our affiliates, vendors, contractors, and personnel from and against any and all claims, liabilities, damages (actual and consequential), losses, and expenses (including attorneys’ fees) arising from or in any way related to your breach of this representation and warranty.

Third-Party Websites

The Services and content provided therein may contain links to other sites and applications, for example, our LinkedIn page and government or industry publications and resources.  Any Personal Data you provide on the linked pages is provided directly to that third party and is subject to that third- party’s privacy policy. Our Privacy Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from the Services.

Procedure to Exercise Your Privacy Rights

This section explains how to exercise the rights that may be provided by applicable laws and under this Privacy Policy.  Many aspects of these data and privacy protection schemes are limited to consumers and are not applicable to you if your interaction with us is commercial, that is not primarily for personal, family, or household purposes.  Our procedures will follow these schemes were applicable to a particular user and/or interaction. 

This procedure applies to the rights that may be afforded in the following jurisdictions which are more fully explained and defined below:

• Nevada – the right to opt-out of Personal Data sales;
• California - rights to access, deletion, and to opt-out of Personal Data sales;
• European Union – right to access, rectification, erasure, withdrawal of consent, portability, objection and restriction of processing, each defined below;

To exercise these rights you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, (2) provides sufficient information to allow us to determine whether you are a consumer as defined by the applicable privacy and data protection scheme if applicable including your location or residence to determine which scheme if any is applicable, and (3) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it including the right you are exercising.  The request may be submitted by email or post at the addresses set forth above under “Contact Information”.  Each request that meets these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request.

We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, and charging a fee are permitted by applicable law, we will notify you of the fee and explain that decision before completing your request.

Changes to this Privacy Policy

We may need to change this Privacy Policy from time to time and will alert you to changes by placing a notice on our Website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. The use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Nevada Resident Rights & Disclosures

If you are a Nevada consumer, you have the rights under the Nevada Revised Statutes Chapter 603A (“NRS 603A”) outlined in this section in addition to those set forth above, where there are conflicts, the portion that is more protective of your Personal Data shall control.

Personal Information Defined

The definition of “Personal Data” used throughout this Privacy Policy includes “personal information” as that term is defined by NRS 603A.040.  NRS 603A.040 defines “personal information” to mean a natural person’s first name or first initial and last name in combination with any one or more of the following data elements, when the name and data elements are not encrypted:

• Social security number.
• Driver’s license number, driver authorization card number or identification card number.
• Account number, credit card number or debit card number, in combination with any required security code, access code or password that would permit access to the person’s financial account.
• A medical identification number or a health insurance identification number.
• A user name, unique identifier or electronic mail address in combination with a password, access code or security question and answer that would permit access to an online account.

Required Disclosures

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

The “How We Share Your Personal Data” section above details the categories of third parties with whom your Personal Data is shared.

The “Sources of Personal Data” and “Information Collected Automatically” sections above detail how we and third parties collect your information through the Services and different websites including by the use of Cookies.

JTW has not and will not sell the Personal Data of Nevada consumers.

The “Changes to this Privacy Policy” section above describes the process by which we will let you know of any changes this Privacy Policy.

The Effective Date of this Privacy Policy is set forth at beginning of the Privacy Policy, immediately below the title.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data.

If you are a resident of Nevada, you have the right to review and request changes to your Personal Data.

Exercising Your Rights

To exercise your right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”

To exercise your right to review your Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.” In response to a Valid Request we will provide you with the specific pieces of Personal Data that we have collected about you.

To exercise your right to request changes to your Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”  Such Valid Request must include the specific items of Personal Data you are requesting us to change, that is the information we have collected and the change to it you are requesting.

We will work to respond to your Valid Request opt-out, review, or change within 60 days of receipt. If we are not able to respond to your request within 60 days, we will let you know that we may need additional time to respond, up to 30 additional days.

California Resident Rights under the California Consumer Protection Act

Our provision of this notice is not deemed our consent or waiver of exemptions from the California Consumer Privacy Act (“CCPA”) that may be applicable to JTW. This section applies only to California residents. 

If you are a California consumer, you have the rights under the CCPA outlined in this section in addition to those set forth above, where there are conflicts, the portion that is more protective of your Personal Data shall control.  Please contact us by post or email if you have any questions about this section or whether any of the following applies to you.  Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes, any such request shall be made by sending a Valid Request following the procedure set forth below under “Exercising Your Rights.” For the avoidance of doubt, JTW does not disclose Personal Data to third parties for such third parties’ direct marketing purposes.

Right to Access

As a California consumer you have the right, but no more than twice in a twelve-month period, to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

• The categories of Personal Data that we have collected about you;
• The categories of sources from which that Personal Data was collected;
• The business or commercial purpose for collecting or selling your Personal Data;
• The categories of third parties with whom we have shared your Personal Data;
• The specific pieces of Personal Data that we have collected about you; and
• If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of the third-party recipient.

Right to Deletion

As a California consumer, you have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Personal Data Sales Opt-Out

You have the right to opt-out of the sale of your Personal Data. To do so send a Valid Request following the procedure set forth below under “Exercising Your Rights.” Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. However, you may change your mind and opt back into Personal Data sales at any time by contacting us.    Please note we do not permit use of our Websites or the Services by persons under 18 years of age – except to the extent a child under 18 is a passenger/guest on services contracted for by or with the consent of their legal guardian.

Exercising Your Rights

To exercise the rights described above, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”

We will work to respond to your Valid Request within 45 days of receipt. If we are not able to respond to your request within 45 days, we will let you know that we may need additional time to respond, up to 90 additional days.

No Discrimination

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you the Services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of the Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

European Union Data Subject Rights

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.   JTW’s services are not currently targeted to or intended for use by persons subject to protection under the GDPR, nonetheless, JTW will utilize reasonable efforts to comply with the requirements of the GDPR.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.  JTW will be the controller of your Personal Data processed in connection with the Services.  If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.  If you have any questions about this section or whether any of the following applies to you, please contact us by email or post at the addresses set forth above under “Contact Information”.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “How We Use Your Personal Data” section above explains how we use your Personal Data.  We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include (1) consent, (2) contractual necessity, (3) our “legitimate interests” or the legitimate interest of others, and (4) other processing grounds based on legal necessity, as further described below.

(1) Consent.  In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data.  When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

(2) Contractual Necessity. We process Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services.  When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.  We process the following categories of Personal Data as a matter of “contractual necessity”:

• A. Personal identifiers
• B. Contact information
• D. Customer records identified by state law
• E. Transaction data
• F. Protected classification characteristics under state or federal law
• I. Sensory data
• J. Business Information
• K. Professional or employment-related information
• L. Age or date of birth
• M. Special categories of data under the EU General Data Protection Regulation

(3) Legitimate Interest.  We process each of the categories of Personal Data in the chart appearing above in the section titled “Categories of Personal Data We Collect” when we believe it furthers the legitimate interest of us or third parties.  Examples of these legitimate interests include:

• Operation and improvement of our business, products, and Services;
• Marketing of our products and Services;
• Provision of customer support;
• Protection from fraud or security threats;
• Compliance with legal obligations; and
• Completion of corporate transactions.

(4) Other Processing Grounds.  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below.  For more information about these rights, or to submit a request, contact us by email or post at the addresses set forth above under “Contact Information.”  Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision.  In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Your rights include the following.

• Access.  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification.  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
• Erasure.  You can request that we erase some or all of your Personal Data from our systems. 
• Withdrawal of Consent.  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of the Services.
• Portability. You can ask for a copy of your Personal Data in a machine-readable format.  You can also request that we transmit the data to another controller where technically feasible.
• Objection. You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing.  You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint. You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.  A list of Supervisory Authorities is available here:  https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Website and other electronic services are hosted and operated in the United States (“U.S.”) through JTW and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to JTW in the U.S. and will be hosted on U.S. servers, and you authorize JTW to transfer, store and process your information to and in the U.S., and possibly other countries.  You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to industry- or technology-specific approved code of conduct blessed by the European Commission.