LeadiD Best Practices + Implementation Guidance

Following some recent court decisions in California and Pennsylvania, we have received questions from partners regarding use of our JavaScript code and disclosures to website visitors. It remains our position that the use of Jornaya LeadiD Create JavaScript is not and has never been a form of wiretapping or invasion of privacy. This communication is intended to help share best practices that we believe create the highest standards of transparency and awareness for consumers. We cannot provide you legal advice and do not intend to do so with this communication; if you have any questions about the law or your legal compliance, we recommend you consult your own counsel.

With that in mind, one of the core tenets of the Fair Information Privacy Principles is transparency. Transparency is best achieved with an explicit website disclosure notifying all visitors that you work with 3rd party technology providers, including session replay technology, and that by using your website, visitors grant express prior consent for their data to be shared with us. This language may already exist in your terms of use or privacy policy but consider whether repurposing a cookie consent pop-up or providing a separate pop-up that links to your privacy policy and terms of service, and expressly requires users to acknowledge both.

Additionally, the best practice implementation of our code is to load the Jornaya LeadiD Create JavaScript only after the consumer has clicked “Accept” or otherwise opted in and provided website and cookie consent. We will continue to partner with all of you to provide solutions that meet best practices. If you have questions, please contact privacy@jornaya.com and we will get in touch promptly.