JBARROWS, LLC

PRIVACY POLICY

Last Updated: May 12, 2020

This Privacy Policy explains how information about you is collected, used and disclosed by jbarrows, LLC (hereinafter “jbarrows”) when you use our websites, mobile applications and other online products and services (collectively, the “Services”) or when you otherwise interact with us.

Jbarrows’ OnDemand video platform is operated by Vimeo OTT Solutions, Inc. (“Vimeo”). Please click HERE to learn more about how Vimeo uses your information.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our websites’ homepages or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

COLLECTION OF INFORMATION

INFORMATION YOU PROVIDE TO US

We collect information you provide directly to us. For example, we collect information when you create an account, use the Services to send or receive messages, including photos or videos uploaded into our Services, request customer support or otherwise communicate with us. The types of information we may collect include your username, password, email address, phone number, age, payment information, and any other information you choose to provide.

When you send or receive messages, we also temporarily collect, process and store the contents of those messages (such as photos, videos, and/or captions) on our servers. The contents of those messages are also stored on the devices of recipients.

INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE THE SERVICES

When you access or use our Services, we automatically collect information about you, including:

USAGE INFORMATION: When you upload content to our Services, we collect information about this content, including the time and date.

LOG INFORMATION: We log information about your use of our websites, including your browser type and language, access times, pages viewed, your IP address and the website you visited before navigating to our websites

DEVICE INFORMATION: We may collect information about the computer or device you use to access our Services, including the hardware model, operating system and version, MAC address, unique device identifier, phone number, International Mobile Equipment Identity (“IMEI”) and mobile network information. In addition, the Services may access your device’s native phonebook and image storage applications, with your consent, to facilitate your use of certain features of the Services.

LOCATION INFORMATION: With your consent, we may collect information about the location of your device to facilitate your use of certain features of our Services, determine the speed at which your device is traveling, add location-based filters to your content, and for any other purpose described in this privacy policy.

INFORMATION COLLECTED BY COOKIES AND OTHER TRACKING TECHNOLOGIES: We use various technologies to collect information, and this may include sending cookies to you. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”).

Below is a list of the cookies we use, and the purposes for which we use them.  Please note that we do not control these cookies .  To find out more information about each cookie, please click on the link provided.

Name of CookieName of PlatformPurpose of CookieMore Information
_gaGoogle AnalyticsThis cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.  Additional resources
_gidGoogle AnalyticsThis cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the wbsite is doing. The data collected including the number visitors, the source where they have come from, and the pages viisted in an anonymous form.  Additional resources
_gat_gtag_UA_39229043_1  Google AnalyticsGoogle uses this cookie to distinguish users.  Additional resources

INFORMATION WE COLLECT FROM OTHER SOURCES

We may also obtain information from other sources and combine that with information we collect through our Services.

USE OF INFORMATION

We may use information about you for various purposes, including to:

  • Provide, maintain and improve our Services, including to provide additional features;
  • Provide and deliver the products and services you request, process transactions and send you related information;
  • Respond to your comments, questions and requests and provide customer service;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by jbarrows and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
  • Link or combine with information we get from others to help understand your needs and provide you with better service;
  • Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity; and
  • Carry out any other purpose for which the information was collected.

jbarrows is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

SHARING OF INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With other users who may access your content;
  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • Where appropriate, we may also share your personal information with selected partners to help us provide you Services, or to fulfill your requests, or with your consent. When selecting our suppliers and partners, we take into account their data handling processes.
  • In response to legal process or a request for information if we believe disclosure is in accordance with any applicable law, rule, or regulation, or as otherwise required by any applicable law, rule or regulation;
  • In order to investigate or remedy potential violations of our user agreements or policies, or to protect the rights, property and safety of jbarrows, our users or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

ANALYTICS SERVICES PROVIDED BY OTHERS

We may allow others to provide analytics services on our behalf. These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand your online activity. 

We currently use Google Analytics which is a web analytics tool that helps us understand how users engage with our Services. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our Services. This information is used to compile reports and to help us improve our Services. The reports disclose website trends without identifying individual visitors.

DO NOT TRACK DISCLOSURE

We do not track our users over time and across third party websites to provide targeted advertising.  We therefore do not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. Your browser should allow you to set its DNT signal so that third parties know you do not wish to be tracked.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

If you are from the European Economic Area (“EEA”), the UK or Switzerland, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so.  In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our Services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.  We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact” heading below.

SECURITY

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of information we collect about you. We maintain organizational, technical and administrative measures designed to protect your information within our organization against unauthorized access, destruction, loss, alteration or misuse. Your information is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please email us immediately at privacy@jbarrows.com.

RETENTION

We retain your personal information as long as we are providing the Services to you. We retain your information after we cease providing Services directly or indirectly to you, even if you close your jbarrows account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain your information to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

INTERNATIONAL TRANSFERS

Personal information may be stored and processed in any country where we have operations or where we engage service providers. We may transfer your information that we maintain about you to recipients in countries other than the country in which the information was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your information remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your information.

If you are located in the EEA, the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA or the UK, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.

CHILDREN

We do not knowingly collect personal information from users under the age of thirteen.

LINKS TO OTHER WEBSITES

The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

YOUR RIGHTS

Depending on the jurisdiction in which you are located, you may have certain rights with respect to your personal information. Subject to applicable law, these rights may include:

  • The right to know what personal information about you we have collected, disclosed, and or sold, as applicable;
  • The right to obtain a copy of your personal information;
  • The right to have your personal information deleted;
  • The right to rectify or update your personal information;
  • The right to restrict the processing of your personal information;
  • The right to object to the processing of your personal information; and
  • The right to withdraw your consent for processing (where processing is based on your consent). Please note that if you withdraw your consent, we may not be able to provide you the services for which it was necessary to process your information based on your consent.

To exercise any of the rights described above, please submit a verifiable request to us by using the contact details provided under the “Contact” heading below.

The verifiable request must describe your request with sufficient detail that allow us to properly understand, evaluate and respond to it, and provide sufficient information that allows us to reasonably verify you are the person about whom we collected the PI or an authorized representative. Please, however, refrain from sending us sensitive PI in your request.

Where permitted by law, you may use an authorized agent to submit a request on your behalf if you have provided the authorized agent signed permission do so. We may not be able to fulfill your request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

We will respond to your request within a reasonable timeframe in accordance with applicable law. We reserve the right to charge an appropriate fee for complying with a request where permitted by applicable law, and to deny a request where it may be manifestly unfounded, excessive, or unwarranted under applicable law.

We hope that you won’t ever need to, but if you do want to complain about our use of personal information, please send us a message with the details of your complaint using the contact details provided under the “Contact” heading below. Applicable laws may also give you the right to lodge a complaint with the data protection authority in your country.  

ACCOUNT INFORMATION

You may update or correct information about yourself by editing your account settings within our Services. If you wish to delete your account, please visit https://jblearn.staging.wpengine.com/account/ but note that we may retain certain information as required by law, for legitimate business purposes, or as part of our regular retention practices. We may also retain cached or archived copies of information about you for a certain period of time.

LOCATION

When you first launch any features of our Services that collect location information, you will be asked to consent to our collection of this information. If you initially consent to our collection of location information, you can subsequently stop the collection of this information by changing the preferences on your mobile device. If you do so, certain features of our Services will no longer function. You may also stop our collection of location information by following the standard uninstall process to remove our Services from your device.

COOKIES

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our website.

PUSH NOTIFICATIONS/ALERTS

jbarrows may, with your consent, send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device (iOS) or by changing your settings within our Services (Android).

CONTACT

To contact us, please send a message to info@jbarrows.com, or write to:

j.barrows, LLC

10 Post Office Square, 8th Floor

Boston, MA 02109