Julota Privacy Policy

 

Your privacy is important to Us.  Touchphrase Development, LLC d/b/a Julota (“Julota”) is committed to maintaining the highest ethical standards and appropriate internal controls.  This privacy policy explains Our online information practices and the choices You can make about the way Your information is used at Our Site (defined below). This privacy policy governs the usage of data provided by You through Your direct use of Our Site.  By using the Site or by providing Julota with information through the Site, You consent to the data practices described in this statement.  This privacy policy is superseded by the terms of any SaaS agreement entered into between You and Julota.

 

1.     Definitions

A. “You”, “Your” and “Yourself” means the individual or entity visiting or using the Site.
B. “We,” “Us”, “Our” and “Ourselves” means Julota.
C. “Site” refers to Julota’s website, www.Julota.com, and other related websites, blogs, domains, and mobile sites maintained by Julota.
D. “Julota” means Touchphrase Development, LLC d/b/a, Julota a Colorado limited liability company.
E. “Non-Personal Information” is any information that is not Personally Identifiable Information.
F. “Personally Identifiable Information” is non-public information We receive from Your use of the Site that can be used, alone or in combination with other information in Our possession, to identify a particular individual.  It may include information such as name, address, telephone number and other personal information You provide Us. It may include protected health information, as defined in HIPAA (“PHI”).
 

2.     Information Collected

A. Information Automatically Collected
Because of the internet communications standards, when You visit the Site We automatically receive certain information from Your browser or mobile device, such as Your browser type, the operating system of Your device, the URL of the site from which You came and the URL of the site You visit when leaving the Site.  We also receive Your IP address and the name of Your ISP or Your mobile carrier.  Depending on Your device’s settings, We may also receive location data and other types of information sent from third-party services or GPS-enabled devices.  As You use the Site, We may also collect information about such usage and Your actions on our Site, such as pages You viewed, access times, and how long You spent on a page.  We may use cookies to collect such information, as described in more detail below.
 

We may use automatic data collection technology to record other information that identifies Your device and tracks Your behavior on the Site.  We may automatically receive and record information on Our server logs from Your browser, including Your IP address, the pages You request, the pages You visited from Our partner and affiliate websites and the products or services You viewed.

 

This information is considered Non-Personal Information We can use for any purpose, including to help Us improve the Site and to enhance Your and other users’ experience.  However, We will treat as Personally Identifiable Information any item that, either alone or together with other information, We could use to identify an individual.  For example, without Your permission, We will not share with third-parties the link between Your IP address and Your Personally Identifiable Information, except as described in Sections 2.C. (“Use of Information”) and 6.B. (“Compliance with Legal Process”) below.


B. Information You Provide
You do not have to provide any Personally Identifiable Information to browse the Site.  However, You may voluntarily send Us information from the Site, including Personally Identifiable Information.  Accordingly, with Your consent, We may collect Personally Identifiable Information about You from the following sources:
 

  • Information You give Us through a contact page, registration form, questionnaires, online interviews, intra-site messaging, or other forms on the Site;
  • Information You send Us by any medium, including texts, mail, telephone, and social media interaction; or
  • If You use a mobile device platform to access the Site or to communicate with Us, information transmitted from Your mobile device.

 

C.  Use of Information 

Julota collects and processes certain voluntarily submitted Personally Identifiable Information for or to enhance the Site or Julota’s educational, networking, social activities, donation processing, store payment processing, and for other similar business purposes.  We may also use Personally Identifiable Information to provide You information regarding news or legal developments We believe may interest You.  Such Personally Identifiable Information is not shared with entities outside of Julota other than service providers who assist Julota in carrying out these business functions or service providers who assist Julota in providing requested services or products.

 

By agreeing to this Privacy Policy and using the Site, You hereby authorize Julota to use or disclose Your Personally Identifiable Information that You provide to Julota or on the Site, and/or You represent and warrant to Julota that You have obtained the necessary authorization and consent to disclose the Personally Identifiable Information that You have disclosed to Julota or on the Site. You further agree that Your disclosure of PHI shall comply with HIPAA and other applicable state and federal privacy laws.

 

Julota may also share Personally Identifiable Information and other data with its service providers, which may include, contractors, consultants and vendors, to help Us perform statistical analysis, send You email, postal mail, provide customer support, arrange for deliveries, operation of the Site technology, internal operations, and other related services in compliance with HIPAA and other applicable state and federal privacy laws; unless You have opted-out of such sharing with these service providers.

 

To enable payment for purchases for products or services from Us, We collect and store name, address, telephone number, email address, credit card information and other billing information. This information will only be shared with third-parties who help to complete the purchase transaction. Examples of this include fulfilling orders and processing credit card payments.

 

Julota keeps track of the pages You visit within the Site for statistical purposes, site optimization, operational decisions, and law enforcement purposes.  This data may also be used to deliver customized content within the Site.

 

Julota will disclose Your Personally Identifiable Information, without notice, for the purpose of preventing criminal activity or disclosing criminal activity, or any other wrongful conduct.  Julota will also disclose Your personal information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Julota or the site; (b) protect and defend the rights or property of Julota; (c) comply with a governmental regulation or lawful demand; and, (c) act under exigent circumstances to protect the personal safety of users of Julota, or the public.

 

Julota may combine Non-Personal Information You provide through the Site with information from other users to create aggregate data. Aggregate data does not (i) contain any information that could identify You, or (ii) include Your personal contact information.


D. Use of Cookies
The Site may send a “cookie” to Your computer.  A cookie is a small piece of data sent to Your browser from a web server and stored on Your computer’s hard drive.  A cookie cannot read data off Your hard disk or read cookie files created by other sites.  Cookies do not damage Your system.  Cookies allow Us to recognize You as a user when You return to the Site using the same computer and web browser.  We use cookies to identify which areas of Our site You have visited.  We also may use this information to better personalize the content You see on the Site.  Julota does not store unencrypted Personally Identifiable Information in the cookies.  We also do not link Non-Personal Information from cookies to Your Personally Identifiable Information.

To help Us optimize the Site, We may allow other authorized third-parties to place or recognize unique cookies on Your browser.  Any information provided to third-parties through cookies will not be Personally Identifiable Information, but may provide general segment information to enhance Your user experience by providing more relevant marketing.  Third-party services and tools We use and which may send cookies to users of the Site, and to collect certain information from users, include:

Google Analytics: Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site.  We use the information We get from Google Analytics only to improve the Site.  Google Analytics collects only the IP address assigned to You on the date You visit the Site, rather than Your name or other identifying information.  You can review Google’s privacy policy at https://www.google.com/policies/privacy/.  We do not combine the information collected through Google Analytics with Personally Identifiable Information.  Although Google Analytics plants a permanent cookie on Your web browser to identify You as a unique user the next time You visit the Site, the cookie cannot be used by anyone but Google.  Google’s ability to use and share information collected by Google Analytics about Your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.  You can prevent Google Analytics from recognizing You on return visits to the Site by disabling cookies on Your browser (see below).

Adobe Creative Cloud (Typekit): The Adobe Creative Cloud (Typekit)is operated by Adobe.  The Adobe Creative Cloud (Typekit) collects anonymous data (ad views, analytics, browser information, cookie data, date/time, serving domains, interaction data and page views), pseudonymous data (IP Address (EU PII), Device ID (EU PII), PII (name, address, phone number, email address, EU- IP address, EU-unique device ID ), sensitive (financial information). Aggregate and anonymous data is shared by Adobe with 3rd parties.  The Adobe Creative Cloud (Typekit) privacy policy can be found at:  http://www.adobe.com/privacy/policies/typekit.html.

Each of the above-listed services and tools listed is governed by the privacy policy established by the respective third-party provider.  We encourage You to refer to such policies, which are linked to above in the description of each service.

Some browsers may allow You to manage the storage of cookies on Your device.  If supported by Your browser, You may set Your browser to refuse all cookies (or, sometimes all third-party cookies) or to alert You when a cookie is set.  However, if You select these settings, You may be unable to access certain parts of the Site.  Unless You have adjusted Your browser setting to refuse cookies, Our system will issue cookies.  For more information about how to manage Your cookies preferences, use the ‘help’ menu of Your web browser or explore the customer support sections of Your web browser.  To opt-out of all cookies or certain advertising cookies, visit the company website for Your browser.  

Here are links to some browsers’ websites:
 

  • Google Chrome: www.google.com
  • Internet Explorer: support.microsoft.com
  • Mozilla Firefox: support.mozilla.org
  • Safari: support.apple.com
  • Opera: www.opera.com


E. Do Not Track Notice—How We Respond to Do Not Track Signals.  
Your browser may provide You with the option to send a “Do Not Track” signal to websites You visit.  This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation.  At the current time, the Site is not programmed to recognize Do Not Track signals, so the Site will not treat You differently if We receive such signals from Your browser and We may not comply with Do Not Track settings on Your browser.

F.  User Generated Content

If Julota makes available to You the ability to comment on content from the Site, post content to the Site, or publish content on a third-party website through a link on the Site, then any information You post will be visible to the public and any Personally Identifiable Information You post may be read, collected and used by third-parties that are not obligated to the terms of this Privacy Policy.  Julota is not responsible for any information You share about Yourself to the public through the Site and Julota has no responsibility to remove or edit information You publish or post to the Site.

 

Further, through the use of APIs that We may utilize, any information You post or publish on or through the Site may be available on other websites or blogs.  Julota is not responsible for any personal information You choose to make public through posting or publishing content on or through the Site, and You agree that such sharing of information will be deemed to have been done by You, not Julota. 

 

3.     Exemptions from Privacy Policy

Our Privacy Policy does not apply to any information You may send to Julota by email or instant messaging programs (e.g., AOL, Yahoo, etc.), or through social media networks, even if You open such programs or services by clicking a link displayed on the Site.  Email, social media, and instant messages are not recognized as secure communication forms.  Please do not send any information You consider private to Us by email or instant message or through social media sites (e.g., Twitter, Facebook, etc.) due to the public nature of such postings.
 

4.     Links to Other Sites

The Site may contain links to other websites.  Julota is not responsible for the actions, practices, or content of websites linked to or from the Site.  You understand such websites may require You to agree to their terms of use and that We have no control over these terms.  As always, You understand it is Your responsibility to verify Your legal use of a website, and use of information from the website with the corresponding website owner
 

5.     Use of Aggregate Data

Julota may combine Non-Personal Information You provide through the Site with information from other users to create aggregate data.  Aggregate data does not (i) contain any information that could identify You, or (ii) include Your personal contact information.  Julota will not disclose Your Personally Identifiable Information, except as otherwise permitted by this Privacy Policy or written agreement.  We require parties with whom We share aggregate data to agree they will not attempt by any means or use of other parties to transform such information into Personally Identifiable Information.
 

6.     When We May Disclose Your Information

Except as set forth in 2.C. above and as set forth below or as specifically agreed to by You, Julota will not disclose any Personally Identifiable Information gathered from You on the Site.

 

A. We may share Personally Identifiable information in a limited fashion to Our contractors, consultants and service providers that perform services on Our behalf or service providers that You have purchased goods or services from directly, in order to provide Our goods or services, including operation of the Site technology, and other related services.  Unless You have opted-out (see Section 6.B. below) of such sharing, these contractors, consultants and service providers also may have access to Your email address.  Access to Your Personally Identifiable Information by such contractors, consultants and service providers is limited to the information reasonably necessary for the contractor, consultant or service provider to perform its limited function for Julota. 

 

B. We may share Personally Identifiable Information We collect (i) when required or advised to do so in response to a valid legal requirement, such as a state or federal law, regulation, search warrant, subpoena, or court order; or (ii) when We suspect criminal or wrongful conduct by a visitor of the Site; or (iii) in special cases, such as in response to a physical threat to You or others, to protect property, or assert legal rights or defend Ourselves in litigation.  If We are legally compelled to disclose Your Personally Identifiable Information to a third-party, We will attempt to notify You unless doing so would violate the law or a court order or result in a potential danger to the public or an individual.

 

C. If You do not want Us to share Your information with Our contractors and service provider, as described above, You can direct Us not to share that information by contacting us.  An opt-out of information sharing will not apply to information sharing arrangements described Section 6.B.

 

7.     CAN-SPAM Compliance Notice

Julota fully complies with the federal CAN-SPAM Act.  You can always opt out of receipt of further email correspondence from Us.  You can elect not to receive emails from Us by following the unsubscribe instructions at the bottom of the email or by contacting Us as indicated below. 
 

8.     Transfer of Ownership

If ownership of the Site or its assets changes, whether in whole or in part, information collected through the Site about You may be transferred to the new owner so the Site and any service provided through or related to the Site can continue.  In that case, Your user information would remain subject to the terms and conditions of Our then current Privacy Policy.
 

9.     Notice to Residents of Countries outside of the United States of America

Julota is headquartered in the United States of America.  Personally Identifiable Information may be accessed by Us or transferred to Us in the United States or to Our affiliates, business partners, merchants, or service providers elsewhere in the world.  Your information collected through the Site may be stored and processed in the United States or any other country in which Julota or its affiliates or service providers maintain facilities. Julota may transfer information that it collects about You, including personal information, to affiliated entities, or to other third-parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If You are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that Julota may transfer information, including Your personal information, to a country and jurisdiction that does not have the same data protection laws as Your jurisdiction, and You consent to the transfer of information to the U.S. or any other country in which Julota or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about You as described in this Privacy Policy.

 

Personal information, which may or may not include Personally Identifiable Information, may be accessed by Julota or transferred to Julota in the United States or to Julota’s affiliates, business partners, merchants, or service providers elsewhere in the world.  By providing Julota with Personally Identifiable Information, You consent to this transfer. 

 

We will protect the privacy and security of Personally Identifiable Information according to Our Privacy Policy, regardless of where it is processed or stored.  If You do not consent to having Your information processed and stored in the U.S., please do not provide it to Julota.

 

10.  California Privacy Rights

Under Section 1798.83 of the California Civil Code, residents of California can obtain certain information from companies with whom they have an established business relationship.  That information is about the Personally Identifiable Information those companies have shared with third-parties for direct marketing purposes during the preceding calendar year.  The law requires companies to inform consumers about the categories of Personally Identifiable Information shared with third parties, the names and addresses of those third-parties, and examples of the services or products marketed by those third-parties.  To request a copy of the information disclosure provided by Julota under Section 1798.83 of the California Civil Code, please contact Us via email to privacy@julota.com. 
 

11.  Children’s Privacy Protection. 

Julota takes special care to protect the privacy needs of children under the age of 13 and Julota encourages parents to be an active participant in their child’s online activities.  Julota abides by the Children’s Online Privacy Protection Act (COPPA) and other relevant laws.  The Site does not target and is not intended for children under the age of 13, and Julota will not knowingly collect Personally Identifiable Information from them.  If Julota discovers personal data from a child gathered through the Site, Julota will eliminate that data.  This Site is not intended for persons under the age of 18.  If You are under 18, You must ask a parent or legal guardian for permission prior to submitting any information to this Site.

 

If You have knowledge that a child 13 years of age or younger has submitted Personally Identifiable Information to Us, please contact Us and We will delete the PII information collected belonging to that child.  You may contact Us via email or by writing to Us at the address below. Parents and guardians can also telephone Us at the address or telephone number provided below, but before any information is disclosed, the parent will be required to provide the parent's name and email address for verification. We will only send the information to the parent email address in the registration file.

 

We will never require the disclosure of a Minor’s personal information.

 

12.  Access

If You are an individual You may have certain rights under applicable data protection legislation, including the right to review and correct the personal data We hold about You.  Unless You reside in California or another jurisdiction that requires Us to provide the information without charge, We may charge You a fee to receive a copy of this data.  For a copy of or reasonable access to Your personal data please contact Us at the address below.
 

13.  Your Acceptance of This Privacy Policy

This is Our entire Privacy Policy for the Site and it supersedes any earlier version.  You agree to it every time You use the Site.

 

If We materially change this Privacy Policy, We will notify You by email or by posting a prominent notice on the Site before the change becomes effective.  We encourage You to periodically review this page for the latest information on Our privacy practices.  Your continued use of the Site or Service constitutes Your agreement to be bound by any changes to this Policy.  Your only remedy, if You do not accept this Privacy Policy, is to discontinue using the Site and service.
 

Changes to the way We use or disclose Personally Identifiable Information will apply on a going-forward basis, unless We have Your express consent to change the way We use or disclose the Personally Identifiable Information We collected when the earlier version of this Privacy Policy was in effect.

 

14.  Security Measures

To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the Personally Identifiable Information We collect, We have implemented physical, electronic, and administrative procedures. These measures are based on commercially reasonable standards that similar companies use.

 

NO DATA TRANSMITTED OVER THE INTERNET, HOWEVER, CAN BE GUARANTEED TO BE 100% SECURE AT ALL TIMES. Although We have implemented security measures to protect Your Personally Identifiable Information, We cannot and do not guarantee the security of such information.

 

15.  European Union Disclosure

Personal information voluntarily submitted to Julota online, via electronic communication, or otherwise, may be maintained or accessed in servers or files in the United States of America, which the European Union has not deemed to provide “adequate” privacy protection.  If You do not consent to having Your information processed and stored in the United States of America, please do not provide it to Julota.
 

16.  Contact Information

Julota welcomes Your comments or questions regarding this Privacy Policy.  If You have any questions regarding this privacy policy or any other policies, You may contact Us by mail or email at:

 

            Julota, LLC

            102 S Tejon Street
            Suite 1100
            Colorado Springs, CO 80903

            Phone:  833-455-1600

            Email: privacy@julota.com

 

Please allow a reasonable period of time for Us to process Your requests to opt out of any data collection practice, to opt-out of emails, or to Your request to review and edit any of Your Personally Identifiable Information.  Whether or not You choose to opt out, Julota may share identifying information and information about Your transactions and experiences within Julota’s affiliate companies.

 

EFFECTIVE DATE:  April 6, 2018