Journera, Inc.
Website Privacy and Cookie Statement
Last Updated: May 15, 2018

Journera, Inc. (“Journera”) is committed to protecting your privacy. This Website Privacy and Cookie Statement (this “Policy”) applies to activities related to your visit to the Journera website (our “website”). This Policy does not describe Journera’s treatment of personal information provided by Providers or other third parties as described in the Journera Privacy Policy.

We encourage you to use the links below to find out more about Journera’s use, collection, and disclosure of information about your visit to this site.

Collection and use of your information

You can visit portions of the Journera site without disclosing your personal information. However, you may choose to provide us with information about you or third parties such as your colleagues, for example when you contact us, register for seminars, activities and programs available on our website, seek employment or when you request information. In these circumstances, we are processing your data for the purposes of taking steps to enter into an agreement with you, or performing that agreement. We may also process your data for other business development purposes (such as considering trends or recording your interest in our service), which are in our legitimate interests.

We may also use this information to carry out business or seek potential business in the future with you or your company. You can ask us not to contact you at any time by emailing us at privacy@journera.com.

When you visit our website, we also may collect, store, process or transfer the following information about your computer: IP address, operating system, browser type, time spent on our respective applications, pages visited, referring URL, language preferences, statistical and traffic data, the Internet address of the website from which you linked directly to our site, and whether you are a return visitor to our site. We may use “cookies”, pixel tags (also known as web beacons and clear GIFs), Adobe Flash technology, device identification, analytical tools and other similar technologies (collectively “Cookies”) to collect this information. Cookies are small data files stored on your device by a website. Cookies help us monitor and improve the functionality and usage of our website and your experience of the website.

We may use third-party web analytics services on our website, such as those of Google Analytics and similar providers. These service providers help us analyze how users use our website, including by noting the third-party website from which you arrive. The information (including your IP address) so collected will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of our website. We may also use such services for purposes related to advertising. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

You can set your browser to turn off “cookies” or to warn you when a website attempts to place a “cookie” on your computer. However, if you turn off the “cookies,” our and other websites may not work as intended. For general information about Cookies including the difference between session and persistent Cookies, visit www.allaboutcookies.org.

We do not recognize or respond to browser-initiated Do Not Track signals.

Cross-border transfer of your information

By visiting Journera’s site, you acknowledge that you are providing information directly to Journera, that is based in the United States, and so information provided or collected from your visit will be stored in the United States, where the privacy laws may not be as protective as those where you live.

We comply with the EU-U.S. 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 European Union and Switzerland to the United States, respectively. Journera has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (the “Principles”). If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/list. The Federal Trade Commission has jurisdiction over Journera’s compliance with the Privacy Shield.

Security of your personal information

Journera uses various organizational and technical measures to protect information collected on our site. However, no transfer of data over the Internet is completely secure. When data is transferred over the Internet, it may be accessed and used by unauthorized third parties. Journera has no control over the performance, reliability, availability or security of the Internet and does not warrant that any information transfer via the Internet or any communication through the Internet is secure. Journera shall not be liable for any disclosure, unauthorized use, loss, damage, expense, harm or inconvenience resulting from the loss, delay, interception, corruption, intervention, misuse or alteration of any personal information due to any action beyond Journera’s reasonable control.

We may retain the information you provide to us via this website whilst you are engaged in communications with us, and for two (2) years thereafter. In certain circumstances, we may be required to retain your information for longer, where law or record keeping requirements requires such retention.

Disclosures to third parties

Journera may share information about you with third parties in the following limited circumstances:

  • Your information may be accessible to third-party service providers processing data on behalf of Journera; however, any such service providers are required by contract to implement reasonable privacy and security safeguards and we remain liable for their compliance with this Policy.
  • Your information may be shared with our corporate affiliates for use consistent with this Policy.
  • We reserve the right to disclose information we receive to government, regulatory, or law enforcement officials or to private parties as we, in our sole discretion, believe necessary to: (i) to satisfy or comply with any applicable law, regulation or legal process, or national security or law enforcement requirements having the force of law; (ii) to respond to lawful requests, including subpoenas, warrants or court orders; (iii) to protect our property, rights, and safety and the rights, property and safety of third parties or of the public in general; and (iv) to prevent or stop activity we consider to be illegal or unethical.
  • We may transfer or disclose all or some of the information discussed in this Policy in connection with a corporate merger, acquisition, lease or sale of assets, bankruptcy or other change in corporate status.

Sensitive personal information

Journera will not generally collect, process or transfer sensitive personal data through its site. “Sensitive personal data” for the purposes of this Policy shall mean data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and data concerning health or sex life. By providing us with unsolicited sensitive personal data, you explicitly consent to such data being collected, processed and transferred by Journera pursuant to this Policy.

Children’s personal information

journera.com is a site not targeted to children and is not intended to collect personal data from children under age of 13.

Access, choice, correction and deletion of personal data

Journera provides you with a possibility to access, update, correct, or delete personal information that you provided to us on this site by contacting Journera at privacy@journera.com. To access, update or delete your data or correct an inaccuracy, we may ask you to verify your identity and cooperate with us in our effort.

Questions or concerns

If you have any questions or concerns about this Policy or the way in which we use your personal information, please contact Journera at privacy@journera.com, or at Journera, Inc., Attn. Privacy Officer, 350 N. Orleans St. #9000N, Chicago, IL 60654. Our data protection officer is also available to help you understand the measures we take to ensure we process your personal information appropriately. You may contact our data protection officer at privacy@journera.com. Because email communications are not always secure, please do not include sensitive information in your emails to us.

Journera is committed to timely resolving complaints about your privacy and our collection or use of your personal information. If we are unable to resolve your concern, Journera has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

As a last resort and in limited situations, EU and Swiss individuals may see redress from the Privacy Shield Panel, a binding arbitration mechanism or to the extent that Journera’s data processing is subject to European laws, you may lodge a complaint with the relevant supervisory authority.

Changes to this policy

Any personal information that we collect is subject to the version of this Policy in effect at the time that information is collected.