1. Scope of this Privacy Notice
Justice Bid, LLC (“JB” or “we”, “us” or “our”) respects your privacy. This “Privacy Notice” informs you of our privacy practices and how your personal information is collected and used by us, and it also informs you of your rights and the options available to you. Where we determine the purposes and means of processing personal information, we act as the data controller. For users located in the EEA, the term personal information used in this Privacy Notice is equivalent to the term “personal data” under the General Data Protection Regulation (“GDPR”).
2. What personal information do we collect?
a. Personal information you give to us
i. When you use our websites
We collect personal information that you provide to us through our website – for example, on our “Contact Us” form, “Request a Demo” form, or other similar online form.
ii. When you use our services
We collect personal information, such as names, e-mail addresses, postal addresses, phone numbers, and job titles, in order to provide you with services (which may include support, professional services, training, etc.). For paid services, we will process financial data supplied to us, such as your bank details.
b. Personal information we collect from participants of a survey conducted by JB
We collect personal information that you, or your employer, provide in response to a survey conducted by JB (“JB Survey Data”). The Operation Empowering Change (“OEC”) initiative only collects deidentified and encoded data that is displayed in the aggregate.
c. Personal information we get from third parties
We may receive personal information about you from third parties. This happens if your employer is a user of our services or signs you up for training, support, or an event. Our third-party partners may also share your personal information with us, with your consent, when you sign up for services through that partner.
We also collect personal information from publicly or commercially available sources, such as LinkedIn. Such personal information may include your name, address, email address, preferences, interests, and demographic data.
d. What happens if you don’t give us your personal information
Much of the information on our websites is available to those who are not our registered users. However, some of your personal information is necessary so that we can supply you with the products or services you have requested and for verification purposes. Therefore, if you don’t provide us with the personal information we need, then we may be unable to supply you with the requested products or the services.
3. Use of our websites and services
4. How do we use your personal information?
Pursuant to data protection laws, we process your personal information where we have a legal basis to do so. The legal basis depends on the reason(s) necessary to process your information.
a. Performance of a contract
We may use the personal information we collect from our customers and their users in connection with the services we provide for a range of reasons, such as:
• setting up a user account;
• providing, operating and maintaining the services; or
• processing and completing transactions, and sending related information, including transaction confirmations and invoices.
We use your personal information in this context based on processing necessary to enter into, or to perform, a contract – Article 6(1)(b) of the GDPR.
b. Legal obligation
We process personal information where we need to comply with a legal or regulatory obligation, such as: maintaining our records, for compliance checks, or screening and recording, for example, for anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions and embargo laws.
c. Legitimate interests
The legal basis we rely on to process your personal information in this specific situation is Article 6(1)(f) of the GDPR. We balance our legitimate interests and the interests of third parties against your rights and interests.
We will use the personal information we collect via our websites:
• to administer our websites and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
• to improve our websites, to ensure that content is presented in the most effective manner for you and for your computer;
• for trend monitoring, marketing and advertising;
• for purposes made clear to you at the time you submit your information; or
• as part of our efforts to keep our website secure.
Our use of your personal information may be based on our legitimate interest to ensure network and information security and for our direct marketing purposes. Our websites may contain links to other sites. If you click on a third-party link, you will be directed to that site. Any external site is not operated by JB and we advise you to review the privacy notice of any external site. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
ii. Business efficacy
We have legitimate business interests, such as:
• conducting general research, including creating or updating aggregate benchmark data sets and reports;
• improving our services and managing our relationships with customers;
• responding to inquiries;
• ensuring our systems and premises are secure;
• managing our supply chain;
• sharing personal information in connection with acquisitions and transfers of our business;
• complying with the law, for example, to comply with a search warrant, subpoena or court order, enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others;
• to address disputes, claims, or to persons demonstrating legal authority to act on your behalf;
• managing your use of the services, responding to enquiries and comments and providing customer service and support;
• sending you technical alerts, updates, security notifications, and administrative communications; or
• investigating and preventing fraudulent activities, unauthorized access to the services and other illegal activities.
We may collect, use and disclose aggregate quantitative data derived from the use of our Services, including without limitation JB Survey Data, for industry analysis, benchmarking, analytics, marketing, and other business purposes. All quantitative data will be deidentified and aggregated and will not identify you, your users, or any third parties utilizing the Services.
In general, responses to RFIs, RFPs, e-Auctions and/or surveys (each, a “Customer Event”) are controlled and managed by the JB customer that sent or deployed such Customer Event. In those instances, we are only processing the responses to a Customer Event on behalf of the JB customer.
When you request a demo or register for a webinar, you agree to us providing you with the information you have requested. You can withdraw this consent at any time by emailing email@example.com. The legal basis we rely on to process your personal information is Article 6(1)(a) of the GDPR.
e. No Automated Decision Making
Your personal information is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal information to evaluate certain conditions about an individual).
5. How we share your personal information
We do not rent or sell your personal information; however, we do share and disclose personal information as described below.
a. Our vendors, consultants and other service providers
We may share your personal information with third-party vendors, consultants and other service providers who perform tasks on our behalf. These companies include (for example) our payment processing providers, website analytics companies (e.g., Google Analytics), email service providers (e.g., Mailchimp), and others.
Where we receive your personal information and subsequently transfer that personal information to a third-party agent or service provider for processing, we require them to have sufficient guarantees in place to protect the privacy and confidentiality of the personal information.
b. Business transfers
We may buy or sell parts of our business and transfer or receive customer information in connection with the evaluation of and entry into such transactions. Also, if we are acquired, go out of business, enter bankruptcy or go through some other change of control, personal information could be transferred to or acquired by a third party. It is our practice to seek appropriate protection for personal information in these types of transactions.
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes for which we collected it. This includes satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you. For further information about our retention periods please contact us at firstname.lastname@example.org.
7. International Data Transfers
Our headquarters are based in the United States. In order to provide our Services, we may store or process your personal information outside your country. Data storage venues may include, without limitation, the United States and the European Union. These and other data storage jurisdictions may operate under privacy and data protection laws different from those of your home jurisdiction. Your submission of personal information through the use of our Services and your consent to this Privacy Notice include consent to such storage and processing outside of your jurisdiction.
We ensure that an adequate level of protection is provided for the protection of personal information by using one or more of the following approaches:
• We transfer personal information to countries that are covered by adequacy decisions from the European Commission or the UK government; or
• We enter into contractual provisions, e.g., Standard Contractual Clauses (SCCs), between us and the recipient, approved by the European Commission or the UK government, as applicable, to impose on the recipient the same protection and security obligations as if they were in the EEA or the UK.
If you are visiting our websites from the EEA, the UK or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States.
8. Data subject rights
Under data protection laws, you have various rights, such as:
• right of access: this gives you the right to ask us for copies of any of your personal information that is in our possession;
• right to rectification: this allows you to rectify and complete information that you think is inaccurate or incomplete;
• right to erasure: this gives you the right to ask us to erase your personal information, if the circumstances allow;
• right to restriction of processing: this gives you the right to restrict or suppress the processing of personal data;
• right to object to processing: this gives you the right to object to processing where there is a compelling reason to do so; and
• right to data portability: this gives you the right to obtain and reuse personal data for your own purposes.
The rights available to you may depend on your location and where the processing of personal information takes place. Please contact us at email@example.com if you want to exercise your rights.
You are not required to pay any charge for exercising your rights, unless your request is unfounded, repetitive or excessive. We will respond to any requests within one month. If we are unable to respond to your request within one month, we will let you know as soon as possible. In the event that your request is unfounded, repetitive or excessive, or if we are not in a position to identify you, we can refuse to act on your request, or charge a reasonable fee.
Direct Marketing Communications
Where consent is used for direct marketing communications, you have the right to withdraw consent at any time.
California residents have the right to know what personal information the business collects, discloses and/or sells if applicable. Under the California Consumer Privacy Act (“CCPA”), consumers have the right to access what personal information has been collected about them by making a verifiable consumer request.
Once we confirm your verifiable consumer request, we will share with you the categories of personal information that we have collected about you in the preceding 12 months, the categories of sources for the personal information we collected, the business or commercial purpose for which the personal information was collected, the categories of our affiliates and/or third parties with whom we share this information, and specific pieces of personal information we collected about you.
If we have sold your information (as defined in the section 1798.140(t) of the CCPA) or disclosed it for a business purpose, we will disclose the sales and disclosures, specifying the personal information category that was sold or disclosed to our affiliates and/or third parties. Furthermore, we will disclose the categories of third parties with whom the information was sold and/or disclosed.
We have not sold (as the term is defined in section 1798.140(t) of the CCPA) personal information in the past 12 months.
As a California resident you have the right to opt out of the sale of your personal information at any time. Subject to some exceptions, you have the right to request that we delete your personal information. You have the right to request that your personal information is transferred to a third party. We will not discriminate against you for exercising your CCPA rights.
Our business operates exclusively online. If you are a California resident and would like to submit a consumer request, please submit a written request to firstname.lastname@example.org.
9. Security of your personal information
To help protect the privacy of personal information you transmit to us, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal information to those employees who need to know that personal information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your personal information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
10. Children’s privacy
We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to register for the services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at email@example.com.
11. Changes to this Privacy Notice
We will post the revised Privacy Notice here, with an updated revision date. If we make significant changes to this Privacy Notice that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our corporate website or social media pages. Your continued use of our websites or services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates. This Privacy Notice was last updated on 15 January 2022 (with previous edits on 24 September 2021 and 28 June 2021).
12. Contacting us & how to make a complaint
We value your opinions. If you have comments or questions about this Privacy Notice, please send them to firstname.lastname@example.org or write to us at the address below. We will treat your requests or complaints confidentially. We will contact you within a reasonable time after receipt of your complaint to address your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Regulatory complaints and redress
Depending on your location, you may have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement.
Justice Bid, LLC
5405 West 127th Street, Ste. B
Crestwood, IL 60418