Jahia Privacy Policy

Last Update: October 13, 2020

We are committed to protecting your privacy and providing a safe online experience.  This Privacy Policy applies to the website located at www.jahia.com and any other web properties and mobile apps which are owned or operated by Jahia Solutions Group S.A. and its affiliates (each individually a “Site”) and to our relationships with our subscribers, partners and vendors.  This Privacy Policy (“Privacy Policy” or “Policy”) informs you of important information about how Jahia Solutions Group S.A and its affiliates ("Jahia,” “we,” “us” or “our”) processes the personal data that we collect in online and offline formats, the privacy practices we undertake, the types of data we collect, how we use and secure that data, and how long we retain that data. 

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site and/or Services (defined below). 

By using our Site and Services (defined below), you expressly give your consent for the collection and use of your Personal Data (defined below) in compliance with this Privacy Policy.

This Policy may change from time to time (see Updates to This Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

When we use the term, “Personal Data,” we mean information or data that directly or indirectly identifies, describes, relates to or is reasonably capable of being associated with or can reasonably link to a particular individual, consumer or household.

When we use the term “Service(s)” we mean to refer collectively to:

  • The provision of our online tools and related services to those who purchase such tools and services (“Subscriber(s)”);

  • The information provided through the Site(s); and

  • Our marketing and business development activities, including any social media properties we create, and emails that we send (“Marketing Activities”).

  1. HOW WE COLLECT YOUR PERSONAL DATA
  2. TYPES OF PERSONAL DATA WE COLLECT
  3. HOW AND WHY WE USE YOUR INFORMATION
  4. HOW WE SHARE AND DISCLOSE PERSONAL DATA
  5. DATA SECURITY
  6. RETENTION OF PERSONAL DATA
  7. CAPACITY / CHILDREN
  8. FINANCIAL INFORMATION
  9. EMAIL MARKETING
  10. YOUR PERSONAL DATA CHOICES
  11. WITHDRAWALL OF YOUR CONSENT
  12. RESPONSE TIMING AND FORMAT
  13. COOKIES NOTICE
  14. YOUR CALIFORNIA PRIVACY RIGHTS
  15. RESIDENTS OF THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM AND SWITZERLAND
  16. DATA CENTERS
  17. LINKS TO OTHER SITES
  18. UPDATES TO THIS PRIVACY NOTICE
  19. HOW TO CONTACT US

 

1. HOW WE COLLECT YOUR PERSONAL DATA

We may collect your Personal Data through different means, when you:

  • Decide to interact with us, either by providing us your information through the registration page, login page or demo page on the Site; by email; regular mail; or telephone;

  • Visit our Site, through automated data tracking technology;

  • View webinars we offer;

  • Become a Subscriber or an authorized user or set up an account and provide us with information directly; and/or

  • Authorize third parties to provide us Personal Data.

It is up to you whether you want to provide us with information or authorize third parties to provide us with information. When we ask you to provide information, you can decline and still visit the Site to learn more about us and what we do. However, if you choose not to provide information to us, we may be unable to provide you our Services. This Privacy Policy does not apply to any third-party sites that may link to or be accessible from the Sites.

 

2. TYPES OF PERSONAL DATA WE COLLECT

We may collect the following types of Personal Data:

a. Types of Information You May Provide to Us:

  • Name, alias, usernames, passwords, physical address, email address, company/employer name, job title, postal address, telephone numbers, communication preferences, unique personal or online identifier, account name, employer, job title;

  • Information that you authorize third parties to release to us;

  • Persistent or probabilistic identifiers that organizations use to identify a particular consumer; and

  • Records of your correspondence with us, including support correspondence.

If you submit any Personal Data to us relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. By submitting Personal Data, you grant Jahia the right to transmit, monitor, retrieve, store and use your information in connection with the operation of the Site.

b. Types of Information We Collect Through Technology:  When you use our Site, we use technology and Google Analytics to gather information on how visitors are using the Site and Services. Specifically, we use technology to gather information about the following:

  • IP addresses

  • Device

  • Internet connection

  • IP address

  • Browser version

  • Time zone

  • Operating system and platform

  • Referring/exit pages

  • Account access date/time stamp

  • Tracker data previously stored on your device

An IP address is a number automatically assigned to your computer whenever you access the Internet. IP addresses allow computers (including mobile devices and tablets) and servers to recognize and communicate with one another. We collect IP address information so that we can properly manage our system and gather information about how our site is being used. This includes the device type and browser you are using, location data, the pages you are viewing and your interactions on the page. Your IP address may be associated with records containing Personal Data. We collect details of visits to our Site, including the volume of traffic received, logs and the resources that you have accessed. We may also collect certain location information such as your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers.   (Please also see our "Cookies Notice".)

c. Types of Information We Collect from Third Parties:  Our Subscribers electronically submit (or cause to be submitted) Personal Data to the Services, which includes names, email addresses, company/employer name, username, password, address, job title.  Our Business Partners may submit Analytics, enhancing data, and customer leads.  We may obtain Personal Information from other third parties, including Integrate, ZoomInfo, LinkedIn, Webikeo and other content syndication vendors.

 

3. HOW AND WHY WE USE YOUR INFORMATION

We only collect the information reasonably necessary to respond to inquiries about our Services, to provide you the Services, to carry out our operations, as required by law, and for the other legitimate business purposes, under applicable laws, as provided below:

  • To inform you about the Services in which you have indicated an interest or to which you've subscribed; Respond to your questions and requests and improve customer service; To provide you with notices about your account and/or subscription, including expiration and renewal notices;

  • To assist in business development and general marketing and building relationships; to create a list of actual and prospective users and Subscribers; to compile statistics regarding how the Site is used in order to improve our products and Services;

  • To record your name and contact information, and other Personal Data for legitimate business purposes, so that we can provide our Services;

  • To authorize and manage access to the Site;

  • To perform our contract with you if you become a Subscriber or authorized user; satisfy contractual necessity to conduct our operations and provide you with the services and products we offer; to perform essential business operations and to manage your account; to contact you with information that may be of interest to you;

  • To improve the Site to provide you with better services, for example, we may use your personal data to improve the layout of our Site based on the click path you utilized to access certain information within the Site; and

  • To comply with legal obligations and professional responsibilities;

  • To verify your identity or conduct internal audits or reviews; and

  • To detect or prevent security incidents or other illegal activity; debug; verify or maintain quality or safety or improve or upgrade a service or device owned or controlled by us.

We do not monitor or profile visitors to our Site or collect, in any automated manner, any special categories of sensitive Personal Data about you.  No automated decision-making, including profiling, is used when processing your Personal Data.

Additional Uses of Personal Data:

In addition to the uses described above, we may use your Personal Data for the following purposes if you become a Subscriber or authorized user.  Some of these uses may, under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to you, or are necessary to serve our legitimate interests in the following business operations:

  • Providing you with newsletters, articles, alerts and announcements, and other information that we believe may be of interest to you;

  • Providing you with marketing information about our services and;

  • Conducting research, surveys, and similar inquiries to help us understand Subscriber or authorized user needs;

  • Analyzing your interactions with us and our Site, and improving our products, services, programs, and other offerings;

  • Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Data, our Site or data systems; or to meet legal obligations; and

  • Enforcing our Terms of Use, Subscription Agreement, and other agreements.

 

4. HOW WE SHARE AND DISCLOSE PERSONAL DATA

We may disclose aggregated information that does not identify any individual (and therefore, is not deemed to be Personal Data) without restriction.  We share Personal Data with the following categories of recipients:

a. Third-party Vendors:  Your Personal Data will only be shared with and processed by our affiliates and non-affiliated third-party service providers as permitted by law and for the purposes described in this Privacy Policy.  We may disclose Personal Data to certain non-affiliated specialized service providers, including professional advisors, consultants, technical service providers, and other third parties, who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.  We may disclose your Personal Data to third-party service providers to provide us with services such as Site hosting, including information technology and telephony services, and related infrastructure, customer service, e-mail delivery, auditing and other similar services. 

b. Corporate Affiliates:  We may share your information with our corporate affiliates that are subject to this policy.

c. Google Analytics:  We share anonymized, aggregated information with Google Analytics.

d. Business Transfers:  When applicable, we may share your information in connection with a substantial corporate transaction, such as the sale of a Site, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

e. Third-Party Advertising:  We may share information with third parties that either display advertising on the Site or manage our advertising on other sites and applications.

f. With Your Consent or at Your Direction:  We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

g. Other Legal Reasons:   In addition, we may use or disclose your Personal Data as we deem necessary or appropriate: (1) under applicable law; (2) to respond to requests from public and government authorities including public and government authorities; (3) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect the rights, privacy, safety or property of Jahia, our affiliates, you and others; and (7) to enforce our terms and conditions.

Jahia keeps Personal Data on file, but does not share, sell, license or transmit this information to third parties or external vendors except to provide our Services and as may be required by legal, judicial or governmental proceedings.

 

5. DATA SECURITY

We use reasonable organizational, technical and administrative measures to maintain the privacy and security of your Personal Data within our organization.  Accordingly, we prevent unauthorized access by a secure firewall and use of security technologies to protect the integrity and privacy of any Personal Data you provide.  For more information, see https://www.jahia.com/trust-center.  Although we work hard to protect your Personal Data, Jahia cannot guarantee the security of any information you transmit to us through online forms and applications, and you do so at your own risk.  Please note that email is considered a nonencrypted (and therefore nonsecure) form of communication, and it can be accessed and viewed by others without your knowledge and permission. For that reason, to protect your privacy, please do not use email to communicate information that you consider confidential.  Unfortunately, no data transmission or storage system can be guaranteed to be secure at all times.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the HOW TO CONTACT US section below. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information. 

We are not responsible for any outcome if you circumvent any privacy settings or security measures. You are responsible for choosing a password of appropriate strength, not reusing passwords used on other websites, not sharing passwords, and keeping your passwords confidential. Jahia employees will never ask for your password.

 

6. RETENTION OF PERSONAL DATA

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy and in order to provide you the Services, and for as long as your account is active or as needed to provide you Services. We will also retain your information to comply with our legal obligations, to conduct audits, resolve disputes, and enforce of our agreements.

 

7. CAPACITY / CHILDREN

This Site is only intended for individuals who are at least 18 years of age.  We do not knowingly encourage or solicit visitors to this Site who are under the age of 18 or knowingly collect Personal Data from anyone under the age of 18.

We are committed to complying with the Children’s Online Privacy Protection Act (COPPA). Our Service is not directed to children under the age of 13 and children under the age of 13 are not to use the Site or provide any information to our Service without express parental consent. We do not knowingly collect personal information from children under the age of 13. If we receive personal information that we discover was provided by a child under the age of 13, we will promptly destroy such information.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see YOUR CALIFORNIA PRIVACY RIGHTS for more information.

 

8. FINANCIAL INFORMATION

We do not retain any personally identifiable financial information or any financial information such as credit card numbers.  In the event that we receive any financial information from you, we will treat it as confidential with appropriate security measures.

 

9. E-MAIL MARKETING

We may periodically send you relevant alerts and newsletters by e-mail. To help improve our Marketing Activities, we often receive a confirmation when you open an e-mail or click on a link included in one of these emails, if your computer supports such capabilities. Instructions on how to unsubscribe from these alerts and newsletters are included in each e-mail.

 

10. YOUR PERSONAL DATA CHOICES

a. Your Rights:  You have choices in how your Personal Data is used and shared. You have the right to:

  • Update, access, correct and/or delete your account information, if you are a Subscriber;

  • Contact us to update, access, correct and/or delete any Personal Data you provided to us if you visited our Site or contacted us;

  • Choose whether you wish to receive promotional and newsletter communications;

  • Choose whether you wish to restrict processing of your Personal Data;

  • Withdraw your consent, if you have given your consent to collect and process your Personal Data; and

  • Complain to a data protection authority about the collection and use of your Personal Data.

  • Deactivate your account and have certain Personal Data deleted.

b. Subscriber Account Information: If you are a Subscriber and have an account with us, you may update, correct, or delete your Personal Data at any time by (1) logging into your account and modifying your Personal Data at https://id.jahia.com/; or (2) by emailing us at privacy@jahia.com. Jahia will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data. We will respond to your access request within 30 days.

c. Certain Exceptions to Deletion Request Rights:  You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.  We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Data, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

d. Choice and Opt-Out:

  • We provide you the opportunity to “opt-out” of having your Personal Data used in for certain purposes and instances. If you no longer wish to receive our newsletters and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by contacting us here. We offer an opportunity to opt-out of certain communications on our member profile page, or you may contact as provided in the HOW TO CONTACT US section below.

  • You will be notified when we share your Personal Data with any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.

  • You may opt out of personalized ads anytime by deleting your browser's cookies. For more information, please review our Cookie Notice.

e. Exercising Access, Data Portability and Deletion Rights:  To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Emailing us at:  privacy@jahia.com, or

  • Writing to us by mail to: Jahia Solutions Group SA, 9 route des Jeunes, 1227 Acacias, Switzerland.

f. Verification of Your Identity:  Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.  You may make a verifiable consumer request for access or data portability twice within a 12-month period. You must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient 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.

 

11. WITHDRAWAL OF YOUR CONSENT

Where you have provided consent to process personal information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.  You may do this by contacting us as set forth in the HOW TO CONTACT US section below.

 

12. RESPONSE TIMING AND FORMAT

We endeavor to respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

13. COOKIES NOTICE

a. You are given the option to opt-out of cookies for certain purposes and instances through the “accept cookies” pop up when you first enter the Site.

b. What are cookies and why are cookies used:  A cookie is a piece of data that a website can send to your browser, which may then be stored on your computer as a tag that identifies your computer. While cookies are often only used to measure website usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any personal information, they are also used at times to personalize a known visitor's experience of a website by being associated with profile information or user preferences. Over time this information provides valuable insight to help improve the user experience.

c. How we use Cookies:  We use cookies and related technologies (“Cookies”) to provide Services, gather information when users navigate through the Sites to enhance and personalize the experience, to understand usage patterns, and to improve our Sites, products, and Services.

d. Types of Cookies:  Cookies on our Sites are generally divided into the following categories:

  • Necessary Cookies.  These cookies are necessary to provide you with our Services and to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Services, you cannot refuse them without impacting how our Services function.  These cookies do not collect identifying information about you, and they do not monitor or remember any of your internet browsing on sites other than Jahia.

  • Helpful Cookies.  These cookies allow us to provide you with a better experience when you use our Site. For example, these cookies provide a getting started guide to interview candidates who have not used Jahia before. These cookies do not collect identifying information about you, and they do not monitor or remember any of your internet browsing on sites other than Jahia.  They may display content from external platforms and interact with online survey platforms. This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

    Examples of applications on the Site that use Helpful Cookies:

    Wistia widget (Wistia, Inc.)

    Wistia is a video content visualization service provided by Wistia, Inc. that allows this Website to incorporate content of this kind on its pages.

    Personal Data processed: Cookies and Usage Data.

    Place of processing: United States. 

    If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

    Hotjar Poll & Survey widgets (Hotjar Ltd.)

    The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd.Hotjar honors generic “Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers.

    Personal Data processed: Cookies, Usage Data and various types of Data.

  • Analytics and Customization Cookies. These cookies collect information to measure traffic and analyze user behavior to improve the Services, to help us understand how our Services are being used or how effective our marketing campaigns are, or to help us customize our Services for you to enhance your experience.  This data is anonymous and only used for statistical purposes, analytics cookies do not collect or share any personally identifiable information. These cookies qualify as “third-party” cookies as they are not sent directly by Jahia.

  • Heat Mapping and Session Recording

    Heat Mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.  Some of these services may record sessions and make them available for later visual playback.

    Examples of applications on the Site that use Heat Mapping and/or Session Recording:

    Hotjar Heat Maps & Recordings (Hotjar Ltd.)

    Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
    Hotjar honors generic “Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers.

    Personal Data processed: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.

    Place of processing: Malta.

  • Targeting Cookies. These record your visit to our Sites, the pages you have visited and the links you have followed to recognize you as a previous visitor and to track your activity on the Sites and other Sites you visit. These Cookies deliver personalized marketing content based on user behavior and to operate, serve and track ads.  These Cookies qualify as persistent cookies, because they remain on your device for us to use during a next visit to our Sites. You can delete these cookies via your browser settings. See below for further details on how you can control third-party targeting cookies. This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User. This activity is facilitated by tracking Usage Data and by using Cookies to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

    Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

    Examples of applications on the Site that use Targeting Cookies:

    Marketo, Bizable, Zoominfo, and 

    LinkedIn Website Retargeting (LinkedIn Corporation)

    LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Website with the LinkedIn advertising network.

    Personal Data processed: Cookies and Usage Data.

    Place of processing: United States.

  • Google Analytics.  This Site uses Google Analytics.  Google Analytics uses cookies to help us to analyze how users use the Site. It counts the number of visitors and tells us things about their behavior in the aggregate – for example, we can see which user guides are most popular or see how many people visit our Sandbox. Google Analytics does not associate your IP address with any other data held by Google.  You may see how Google uses data when you use this Site at www.google.com/policies/privacy/partners.

e. How to Control Cookies:  You can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain Cookies. If you choose to block all cookies, you may not have access to our Site, our Services will not function as intended, and you will not be able to log in. If you have blocked all cookies and wish to make full use of the features and Services we offer, we recommend enabling at least first-party cookies. Rather than blocking all cookies, you can choose to block only third-party cookies. This will allow Jahia Services to function as intended.  To learn more about the use of Cookies by Google for analytics see https://policies.google.com/technologies/cookies.  To exercise choice regarding those Cookies, please see the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. The opt-outs described above are device- and browser-specific and may not work on all devices.

f. Advertising industry specific opt-outs:

Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document. The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

 

14. YOUR CALIFORNIA PRIVACY RIGHTS

a. CCPA:  As of January 1, 2020, under the California Consumer Privacy Act (CCPA), California Residents have certain additional rights regarding their Personal Data. If and to the extent you are a "consumer" as defined under the CCPA and that we are a "business" as defined under CCPA, the following may apply to you:

You have the right to request the following information from us by emailing us at the contact information in the section titled, HOW TO CONTACT US, and we will provide the following information to you upon verification of your identity:

  • The categories of Personal Data we collect about you;

  • The categories of sources from which your Personal Data is collected;

  • The business purpose for collecting your Personal Data;

  • The categories of third parties with whom we share your Personal Data; and

  • The specific pieces of Personal Data we have collected about you.

In addition, please check the following sections of this Privacy Policy: TYPES OF PERSONAL DATA WE COLLECT, HOW AND WHY WE USE YOUR INFORMATION, and HOW WE SHARE AND DISCLOSE PERSONAL DATA.

You may opt out of any marketing by us and from the disclosure of your Personal Data to third parties.

b. Personal Data Sales Opt-Out and Opt-In Rights:  If you are 16 years of age or older, you have the right to direct us to not sell your Personal Data at any time (the “right to opt-out”). We do not sell Personal Data.  If this changes in the future, we do not, and will not, sell the Personal Data of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age.  Consumers who opt-in to Personal Data sales in the future may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing privacy@jahia.com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Data sales. However, you may change your mind and opt back into Personal Data sales at any time by contacting us.  You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Data provided in an opt-out request to review and comply with the request.

c. Non-Discrimination:  If you elect to exercise any of your rights under CCPA, we will not discriminate against you for exercising any of your CCPA rights.  Unless otherwise permitted by the CCPA, we will not: deny you goods or services, charge you a different price or rate for our goods or services, or provide you a different level or quality of goods or services because you exercised such rights. Under the current definition of CCPA, Jahia does not sell your Personal Data.

d. Other than as provided above, we may offer you certain financial incentives, as permitted by the CCPA, in exchange for your giving us certain information, which incentives may result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Data’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

15. RESIDENTS OF THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM AND SWITZERLAND

Your personal information will be treated in a secure and confidential manner in compliance with all applicable laws and regulations, including the European General Data Protection Regulation (“GDPR”).  Depending on the context in which personal information is provided, Jahia may be the data processor (“processor”) or data controller (“controller”) of your personal information. In most instances, Jahia is a processor of personal information submitted to the Site or collected through the Site on behalf of or at the direction of our Subscribers. The Data Subject owns the data submitted to the Service.  If the Subscriber requests that Jahia remove the personal information, we will respond to the request within 30 days.

If you have any questions or concerns regarding this Privacy Policy or our privacy practices, including the processing of your personal information, if you would like to exercise your data rights under applicable laws, or if you believe your privacy rights have been violated, please contact us as provide in the section "How to Contact Us" below.

 

16. DATA CENTERS

The Site is hosted in the European Union.  Jahia maintains data centers for its Subscribers within the European Union and the United States.  Subscribers may choose their hosting location that Jahia offers.  Jahia adopts the Standard Contractual Clauses as part of our commercial agreements as needed.

 

17. LINKS TO OTHER SITES

Occasionally we may provide links to other sites for your convenience and information. These sites operate independently from our Sites and are not under our control. These sites may have their own privacy notices or terms of use, which you should review if you visit any sites linked through our Sites. We are not responsible for the content or use of these unrelated sites.

 

18. UPDATES TO THIS PRIVACY NOTICE

Jahia may change its Privacy Policy from time to time, and at Jahia's sole discretion. Jahia encourages visitors to frequently check this page for any changes to its Privacy Policy.

 

19. HOW TO CONTACT US

If you have any queries, questions or concerns about this Privacy Policy or our Personal Data handling practices, please write to us at Jahia Solutions Group SA, 9 route des Jeunes, 1227 Acacias, Switzerland; or contact us via email at privacy@jahia.com.