Privacy Policy

Effective Date: May 12, 2018

Introduction

This Privacy Policy describes the policies and procedures of JOOR, Inc. ("JOOR", "we", "our" or "us") on the collection, use and disclosure of the information of business entities and wholesale customers on http://jooraccess.com (the "Site") and the services, features, content or applications we offer (collectively with the Site, the "Services"). We receive information about you from various sources, including: (i) if you register for the Site and the Services, through your user account on the Services (your "Account"); (ii) your use of the Services generally; and (iii) from third party websites and services. When you use the Services, you are consenting to the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction and other uses of your information as described in this Privacy Policy.

Principle of the JOOR Privacy Policy

JOOR does not rent or sell your Personal Information. We don't share your Personal Information with anyone except to comply with the law, to provide a service you have requested, to protect our rights, or as provided in this Privacy Policy. We don't store Personal Information on our servers unless required for the on-going operation of one of our Services.

What this Privacy Policy Covers

This Privacy Policy covers the treatment of personally identifiable information ("Personal Information") gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners. This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications ("Third Party Services") that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

We value the privacy of your Personal Information, and we have accordingly addressed the European Union’s General Data Protection Regulation (GDPR). The GDPR gives individuals in the EU more control over how their data is used, and it places certain obligations on businesses that process Personal Information of those individuals. We have updated this Privacy Policy to take into account the requirements of the GDPR.

What Information Do We Collect?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.

ACCOUNT INFORMATION

JOOR collects Personal Information, such as your email address, when you create an Account with JOOR to use the Services. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous.

USER CONTENT

Some features of the Services allow you to provide content to the Services, such as written comments. All content submitted by you to the Services may be retained by us indefinitely, even after you terminate your account, unless the content contains Personal Information, in which case you can request that the content be provided to you and/or deleted. We may continue to disclose such content to third parties in a manner that does not reveal Personal Information, as described in this Privacy Policy.

IP ADDRESS INFORMATION AND OTHER INFORMATION COLLECTED AUTOMATICALLY

JOOR receives and records information on our server logs from your browser, including your IP address, cookie, and the page you request in order to operate the Services. JOOR may use analytic tools or services to view aggregate statistics about the usage of the Services. Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser. IP Addresses are automatically reported by your browser each time you view a web page. IP addresses may be used for various purposes, including: To diagnose or service technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP. To tailor advertising based on geographic area or other information derived from your IP address. Aggregate information derived from IP addresses may also be reported to advertisers. To estimate the total number of users visiting the Services from specific geographical regions.

COOKIES

A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a web site's computers and stored on your computer's hard drive. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. JOOR uses its own cookies for a number of purposes, including to:

— Access your information when you "sign in".
— Keep track of preferences you specify while you are using the Services.
— Keep track of your design file choices.
— Store credentials you may use to enable posting to other sites.
— Estimate and report our total audience size and traffic.
— Conduct research to improve JOOR's content and services.

Since JOOR uses cookies to track, diagnose and service technology problems reported by our users or engineers, if you reject all cookies, you will not be able to use the parts of the Services that require you to "sign in," and you may not be able to take full advantage of the Services. Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Information Sharing and Disclosure

When you access or use the Services, we collect, use, share, and otherwise process your personal information as described in this Privacy Policy. We process your personal information when you have given consent to the processing and when the processing is necessary:

— For us to provide the Services to you.
— For compliance with a legal obligation.
— To protect the vital interests of yourself or others.In the public interest.
— For the purposes of our legitimate interests or those of a third party.

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Site or otherwise through the Services, such as on message boards, in reviews and discussion areas, and within your public profile page. Such content becomes publicly available and can be collected and used by others. Registered users may have some of this public information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us. If you post Personal Information online in a way that is accessible to the public, you may receive unsolicited messages from other parties in return. JOOR does not rent or sell your Personal Information.

Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.
User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services.

We do not use your email address or other Personal Information to send marketing messages unless you've opted in to receive such messages. We may, however, use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major Site changes, alerting you to messages from other members of the Services, or for customer service purposes). We use both your Personal Information and certain non-personally-identifiable information (such as anonymous user usage data, cookies, IP addresses, browser type, clickstream data, etc.) to improve the quality and design of the Site and to create new features, functionality, and services by storing, tracking, and analyzing user preferences and trends.
As stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

JOOR will not share Personal Information about you with other people or other companies without your consent except to provide products or services you've requested and in the following circumstances:
JOOR may be required to disclose Personal Information and/or non-personally identifiable information under special circumstances, such as to comply with state and federal laws (such as U.S. Copyright Law), subpoenas, warrants, court orders or legal process or to establish or exercise our legal rights or defend against legal claims.

It may be necessary to share information in order to investigate, prevent, or take action regarding suspected or actual illegal activities, including without limitation, fraud, situations involving potential threats to the physical safety of any person, violations of JOOR's Terms, or as otherwise permitted or required by law.

JOOR reserves the right to disclose Personal Information and/or non-personally-identifiable information that JOOR believes, in good faith, is appropriate or necessary to enforce our Terms, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our Site, and to protect the rights, property, or personal safety of JOOR, our users or others.

We will transfer information about you if JOOR is acquired by or merged with another company. In this event, JOOR will notify you by email or by putting a prominent notice on the Site before information about you is transferred and becomes subject to a different privacy policy. In the event that JOOR is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your Personal Information is treated, transferred, or used.

JOOR may share demographic information with business partners, such as "53% of users who regularly use JOOR are boutiques" or the like. No Personal Information will ever be used without your permission when sharing such demographic information (i.e. we will ask you for a quote or testimonial).

JOOR may contract with various third parties who help us provide and maintain the Site or the Services (our "Agents"). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents. We will use commercially reasonable efforts to prevent such third parties from disclosing your Personal Information, except for the purposes of providing the services in question. We cannot, however, guarantee that such third parties will not disclose our Personal Information and will not be liable for any unauthorized use or disclosure by any third party.

We limit access to Personal Information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

Editing and deleting Account Information

You can delete your Account username at any time. You can edit and change other Account information at any time. You can delete your Account at any time from your Account page; however, please note that your identification and contact information may remain in JOOR's records for some period. If you delete your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public unless requested to be removed.

Data Security & Change of Control

Your Account information is password-protected. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account. JOOR uses commercially reasonable physical, managerial, and technical safeguards, such as commercially available encryption protocols, to preserve the integrity and security of your Personal Information. We cannot, however, ensure or warrant the security of any information you transmit to JOOR and you do so at your own risk. Once we receive your transmission of information, JOOR makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If JOOR learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. JOOR may post a notice on the Site if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us using by completing the Contact Us form with the appropriate request.

What Information of Mine Can I Access?

If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings. California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 1239 Broadway, 9th Floor, New York, NY 10001.

What Choices Do I Have Regarding My Information?

You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features. You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.

You can ask us to confirm whether or not your personal information is being processed and, if so, to provide you with access to the information and an explanation of the purposes of the processing, the categories of personal data concerned, the categories of recipients of the data, and the period for which the data are stored. You can also withdraw your consent or object to the processing of your personal information, request that we correct or delete your personal information, or obtain a copy of your personal information from us.

Changes & Updates To This Privacy Policy

This Privacy Policy may be revised periodically with or without notice to you and this will be reflected by the "effective date" above. Please revisit this page to stay aware of any changes. In general, we only use your Personal Information in the manner described in the Privacy Policy in effect when we received the Personal Information you provided. Your continued use of the Site constitutes your agreement to this Privacy Policy and any future revisions. For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of the Personal Information you have already provided to us, we will attempt to obtain your consent before implementing such revisions with respect to such information.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to support@jooraccess.com. We will make every effort to resolve your concerns.

Privacy Shield

JOOR, Inc. participates in and has certified that it complies with the E.U.-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the E.U. to the U.S. JOOR, Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (“Principles”). JOOR, Inc. is committed to subjecting all Personal Information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s Principles.

To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov. In compliance with the Principles, this Privacy Policy sets out:

— The types of Personal Information we collect (“What Information Do We Collect”)
— The purposes for which we collect and use Personal Information (“What Information Do We Collect”)
— The types of third parties to which we disclose Personal Information, and the purposes for which we do so (“Information Sharing And Disclosure”)
— Our liability for onward transfers to third parties (“Information Sharing And Disclosure”)
— The choices and means we offer individuals for limiting the use and disclosure of their Personal Information (“What Choices Do I Have Regarding My Information”)
— The right of individuals to access their Personal Information ("What Information Of Mine Can I Access")

JOOR, Inc. is responsible for the processing of Personal Information it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf, if any. JOOR, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

E.U. data subjects may contact us for the handling of complaints, access requests, and any other issues arising under Privacy Shield as specified in the “Contact Us” section below. If you have a complaint regarding our compliance with the Principles, first contact us to informally resolve your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) https://www.jamsadr.com/eu-us-privacy-shield . As further explained in the Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means. JOOR, Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, JOOR, Inc. may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.