Effective on January 1, 2020

Privacy Policy for Consumers

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PRIVACY POLICY FOR CONSUMERS

This Privacy Policy for Consumers (“Consumer Privacy Policy”) is provided by Lead Intelligence, Inc. d/b/a Jornaya (“Jornaya,” “we,” “us,” or “our”) to inform interested parties who happen to visit our website at jornaya.com know what information is collected through our proprietary Platform for the products/services we provide our Clients (as further defined below), how it’s collected, and how we protect it, use it, and share it as applicable. It also describes choices available to Consumers regarding protecting your information and how to opt-out of Internet-based advertising services.

For our purposes, “Consumer” refers to an individual who visits and interacts with a third party website or application, such as a website operated by a Publisher (as further defined below) on which the individual indicated an interest in a particular product or service and provided contact information in response to a form or questionnaire, as well as browsed or otherwise interacted within such sites.

Please Note: If you are a Jornaya Client (i.e. Publisher, Querier or Partner), please visit our Privacy Policy for Services by clicking here or by visiting our website at jornaya.com.

WHAT WE DO

Jornaya provides a proprietary technology Platform, including any scripts or code provided by Jornaya (“Scripts”), and any products/services provided by Jornaya (“Services”) (collectively the “Platform”), which allows our Clients (as further defined below) who are sharing their data with one another to (i) verify the data’s origin and history, (ii) help advertisers, vendors and marketers analyze first, second and third-party consumer (“Consumer(s)”) interactions to, for example, focus their attention and efforts on consumers who may be interested in certain products and/or services, and (iii) supplement our Services with related services provided by our strategic partners. If the Consumer’s browser allows it, a persistent cookie is dropped so that the same browser can be identified in future events and tied to a LeadiD or other identifiers. For additional information about how our Platform works, please review the Terms of Use, located on our website at jornaya.com.

OUR RELATIONSHIP TO CONSUMERS

JORNAYA PROVIDES ITS PLATFORM TO OUR CLIENTS, NOT DIRECTLY TO CONSUMERS. WE HAVE NO DIRECT RELATIONSHIP, INCLUDING ANY ESTABLISHED BUSINESS RELATIONSHIP, WITH CONSUMERS. THIS CONSUMER PRIVACY POLICY APPLIES ONLY TO OUR PLATFORM. JORNAYA DOES NOT CONTROL THE PRIVACY POLICIES OF OTHER WEBSITES OR PARTIES CONSUMERS MAY INTERACT WITH, INCLUDING THOSE OF OUR CLIENTS. WE ENCOURAGE CONSUMERS, AND WE EXPECT OUR CLIENTS TO ENCOURAGE CONSUMERS, TO READ ALL APPLICABLE TERMS AND CONDITIONS, POLICIES AND/OR STATEMENTS OF THE WEBSITES CONSUMERS VISIT, ESPECIALLY THOSE WEBSITES THAT COLLECT PERSONAL INFORMATION FROM CONSUMERS (“CONSUMER PI”).

Our collection, processing, use, and storage of Consumer PI is dependent upon our Clients implementing our Scripts and/or Services on their Publisher Platforms, which we do not control. Under our Terms of Use, if our Clients use our Platform in connection with their collection and use of Consumer PI, they must comply with all applicable laws, including, where applicable, publishing and complying with an adequate privacy policy that discloses the use of our Platform and how our Platform collects and processes data, as described in our Terms of Use and Privacy Policies. To the extent required by law, Publishers must provide detailed information about, and ensure Consumers consent to, the storing and accessing of cookies or other information on the Consumer’s device in connection with use of our Platform on the Publisher Platforms. Our Clients are not permitted to circumvent any opt-out options or other privacy features of our Platform; and are solely responsible for ensuring that they have permission from Consumers to use any Consumer PI (for example, name, email, phone, address) in connection with their access and use of our Platform.

OUR CLIENTS

We have three types of Clients who access, use and interact with our Platform in different ways, as follows:

“Publishers” are companies who are accessing and using the Services to create Universal LeadiDs (as further defined below) on their own web site(s) or platform(s) (“Publisher Platforms”).

“Queriers” are companies who generate data on their own or receive data from another party with a Universal LeadiD or other identifiers (“Identifiers”) and desire to verify and/or append certain attributes to the Identifiers by querying our network. A Querier can also be a Publisher.

“Partners” are companies who work with Jornaya to provide supplemental services to Publishers or Queriers through our Services, either by incorporating certain aspects of our Services, or by integrating with our Services. Partners may contribute their own data or access data via APIs, SDKs, web related services. In some cases, we may use Partner pixels, cookies, scripts or tags alongside our Script.

HOW WE COLLECT, STORE AND USE CLIENT DATA

Many Publisher Platforms utilize our Services. When you visit, enter information into, or otherwise interact with a Publisher Platform, the technology associated with our Services (previously installed by the Publisher at a Publisher Platform with that Publisher’s approval) captures certain information and automatically creates and returns to the Publisher a unique lead identifier known as a “Universal LeadiD”. The Services may use various technologies to do this, including JavaScript®, website scripts, pixel tags, cookies, local storage, and device identification. The information associated with a Universal LeadiD is subject to confidentiality obligations at all times.

If you enter information into an open text field within a form on a Publisher Platform, our Services automatically encrypt that information using a cryptographic hash function which makes it infeasible for anyone, including us, to store, retrieve, reverse-engineer, or utilize the information that you volunteered.

We collect and encrypt the following categories of information: