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Data Agreement

Seniornicity Privacy Policy 2024

 

Last updated: July 9, 2024

Welcome to www.seniornicity.com (the “Site”), owned and operated by Jantsons, Inc. (“Jantsons”, “we”, “us”, or “our”). Your privacy is important to us. It is Jantsons’s policy to respect your privacy and comply with any applicable laws and regulations regarding any personal information we may collect about users of the Site, (“user(s)”, “you”, “yourself”, or “your”), including across the Site and other sites we own and operate. Jantsons offers a referral listing site for seniors, connecting them with various service providers (the “Services”).  

This Privacy Policy applies to personal information collected by us through our Site, in person, electronic mail, or mail. 

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, phone number and date of birth), your devices, payment details, email address, and even information about how you use a website or online service.

  1. Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

  1. Log Data

When you visit the Site, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the Site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

  1. Device Data

When you visit the Site or interact with our services, we may automatically collect data about your device, such as:

  • Device Type
  • Browser Type
  • Operating System
  • Device settings
  • Geo-location data

Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

  1. Personal Information

In certain instances, we may ask for personal information — for example, when you sign up for a membership, subscribe to our newsletter, or when you contact us. We collect the following personal information from you when you voluntarily provide it to us:

  • Name
  • Email
  • Mailing Address 
  • Phone number
  • Jantsons membership profile information
  • Payment information for membership purchases
  • Other similar membership information 
  1. Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

  1. Collection and Use of Information

We may collect personal information from you when you do any of the following on the Site:

  • Sign up to receive updates from us via email or social media channels
  • Sign up to be a member of Jantsons’ Site or referral service provider
  • Use a mobile device or web browser to access our content
  • Contact us via email, social media, or on any similar technologies
  • When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to provide you with our platform’s core features and services
  • to enable you to customize or personalize your experience of the Site
  • for analytics, market research, and business development, including to operate and improve the Site, associated applications, and associated social media platforms
  • for advertising and marketing, including to send you promotional information about our events and services and information about third parties that we consider may be of interest to you
  • for internal record keeping and administrative purposes
  • to comply with our legal obligations and resolve any disputes that we may have

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use the Site to improve the Site and your experience on it.

  1. Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring you do not make your personal information publicly available via our platform.

  1. How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information such as an email address when contacting us about a specific inquiry, we may retain this information for the duration of your inquiry remaining open as well as for our own records so we may effectively address similar enquiries in future. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes for up to 7 years after your last interaction with us, unless a longer retention period is required or permitted by law..

  1. Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13. If you are a parent or guardian and believe that Jantsons has information of a child under the age of 13, please contact us immediately at support@jantsons.com so we can use our best efforts to remove any such information from our database.  

  1. Disclosure of Personal Information to Third Parties

We may disclose personal information to:

  • a parent, subsidiary, or affiliate of our company
  • third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
  • our employees, contractors, and/or related entities
  • our existing or potential agents or business partners
  • credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
  • courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
  • third parties to collect and process data
  • third parties who assist with the enforcement of our Terms of Use and other agreements, who help protect our rights, property, or safety, and those of our users, and others, including for fraud protection.
  • an entity that buys, or to which we transfer all or substantially all of our assets and business
  1. Third parties we currently use include but may not be limited to:

Google Analytics

  • We use Google Analytics to monitor and analyze the use of our Site. Google Analytics is a web analytics website offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Site. This data is shared with other Google websites. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
  • You can opt-out of having made your activity on the Site available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, you can view their privacy policy by clicking here. http://www.google.com/intl/en/policies/privacy/

MailChimp

  • We may use MailChimp to communicate with you, like when you receive our email newsletter. You can view their privacy policy by clicking here. https://mailchimp.com/legal/privacy/

Each of these services has their own privacy policies, which we encourage you to review.

  1. International Transfers of Personal Information

The personal information we collect is stored and/or processed in the United States, or where we or our partners, affiliates, and third-party providers maintain facilities.

The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

  1. Controlling Your Personal Information

13.1. Your choice.

By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. If you choose not to disclose your personal information, it may affect your use of the Site or the products and/or services offered on or through it.

13.2. Information from third parties.

If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

13.3. Marketing permission. 

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.  Please place “General Privacy Request” in the subject line.

13.4. Access.

You may request details of the personal information that we hold about you by contacting us using the details below.  Please place “General Privacy Request” in the subject line.

13.5. Correction. 

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided below. Please place “General Privacy Request” in the subject line. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

13.6. Non-discrimination.

We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

13.7. Data Breach.

To the fullest extent permitted by law, in no event will Jantsons, nor its directors, employees, agents, or affiliates, be liable for any indirect, incidental, special, consequential or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from (i) your access to or use of or inability to access or use the services; (ii) any conduct or content of any third party on the services; (iii) any content obtained from the services; and (iv) unauthorized access, use or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence) or any other legal theory, whether or not we have been informed of the possibility of such damage, and even if a remedy set forth herein is found to have failed of its essential purpose. This limitation of liability does not purport to limit liability in a manner that would violate the rights of consumers under the California Consumer Privacy Act (“CCPA”) or any other applicable law. Jantsons will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of the website or the service or items obtained through the website or the service or to your downloading of any material posted on it, or on any website linked to it.

13.8. Notification of data breaches.

We will comply with laws applicable to us in respect of any data breach. Jantsons will not be liable for any damages resulting directly or indirectly from the unauthorized access, disclosure, or misuse of data, nor will Jantsons be liable for any losses or damages arising from the actions of third parties beyond Janstsons’ reasonable control, including but not limited to cyberattacks, phishing scams, or other malicious activities.

13.9. Complaints.

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. Please place “General Privacy Request” in the subject line. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You may also have the right to contact a regulatory body or data protection authority in relation to your complaint.

13.10. Unsubscribe.

To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this Privacy Policy.  Please place “General Privacy Request” in the subject line, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity. You may also use the unsubscribe link located at the footer of the email you receive. 

  1. Use of Cookies and Tracking Technologies

We use “cookies” and other similar tracking technologies to collect information about you and your activity across the Site. These technologies include: (a) Session cookies, which are temporary and expire once you close your browser; (b) Persistent cookies, which stay on your device until you delete them or they expire; and (c) Web beacons, which are tiny graphics with a unique identifier, used to track user activities. A cookie is a small piece of data that The Site stores on your computer, and accesses each time you visit, so we can understand how you use the Site. These alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser enable our systems to recognize your browser, to provide certain features. This helps us serve you content based on preferences you have specified. You may decline cookies from the Site if your browser permits. Your browser may allow you to activate settings to refuse the setting of all or some cookies.  If you decline cookies, you may still use the Site, but you may not be able to use some portions of the Site

  1. Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

  1. Limits of Our Policy

In the event the Site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave the Site. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

  1. Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes from time to time. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically for any changes.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

  1. Additional Disclosures for General Data Protection Regulation (GDPR) Compliance 

If you are in the European Union, the following disclosures may apply to you: 

18.1. Data Controller / Data Processor

The GDPR distinguishes between organizations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”).  ASIFA-Hollywood, located at the address provided in the Contact us section, is a Data Controller with respect to the personal information you provide to us.

18.2. Legal Bases for Processing Your Personal Information

We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose. Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

18.3. Consent From You

Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities We provide; however, this will not affect any use of your information that has already taken place. You may consent to providing your email address for the purpose of receiving marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact us section of this privacy policy.

18.4. Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require personal information such as your name and contact details in order to respond.

18.5. Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

18.6. Compliance with Law

In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

18.7. International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

18.8. Your Rights and Controlling Your Personal Information

Subject to certain conditions, and depending on your location, you may have certain rights regarding your personal information, including the following:

18.8.1. Right to Access: You have the right to request copies of your personal data from us. We may charge you a small fee for this service. 

18.8.2. Right to Rectification: You have the right to request us to correct information you believe is inaccurate. You also have the right to request that we complete information that you believe is incomplete. 

18.8.3. Right to Erasure: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of the Site or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. 

18.8.4. Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

18.8.5. Objecting to processing: You have the right to object to the processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.

18.8.6. Data portability: You have the right to request a copy of the personal information you have provided to us to be provided to you and/or another data controller, and that the format of such information be in a structured, commonly used and machine-readable format.

We have 30 days to respond to you if you make a request. To exercise any of these rights please contact us using the information provided in the "Contact Us" section below.  Please place “GDPR Request” in the subject line.

  1. Additional Disclosures for California Compliance (US)

Under California’s “Shine the Light” law, California Civil Code § 1798.83, if you are a California resident California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes.

To make such a request, please contact us via email at support@jantsons.com with “Request for California privacy information” in the subject line. you may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organizations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by § 1798.83 of the California Civil Code. 

  1. Do Not Track

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.

We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

  1. Contact Us

For any questions or concerns regarding your privacy, you may contact us by emailing:

Privacy Compliance Team

support@jantsons.com 

Or write to us at:

Privacy Compliance Team

2901 W Coast HWY, Suite 200

Newport Beach, CA 92663

  1. California Consumer Protection Act (“CCPA”) Privacy Notice

22.1. Exercising Your Rights under the CCPA

 If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”). This policy explains the tools that we have made available to you to exercise your data rights under the CCPA, including such as the rights to request information about how we process your personal information, request deletion and the right to request access to the specific pieces of categories of personal information we have collected about you.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose about you, (2) request deletion of your personal information, (3) opt out of any sales of your personal information, if we engage in that activity in the future, and (4) not be discriminated against for exercising these rights.

22.2. What Personal Information Do We Collect, Share, and/or Sell and for What Purpose?

In the past 12 months, we may have collected and shared the following types of personal information and sensitive personal information:

  • Name
  • Email
  • Mailing Address 
  • Phone number
  • Jantsons membership profile information
  • Payment information for membership purchases
  • Other similar membership information 

We may also use or share de-identified information that is not reasonably likely to identify you for commercially legitimate business purposes.

We retain your personal information for as long as necessary to carry out the business purposes described in this policy, or as otherwise required under law. The length of retention may vary depending upon factors such as recordkeeping or legal compliance requirements, the need to resolve inquiries or complaints, and the existence of an ongoing relationship with you.

22.3. Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes other than permitted under applicable law.

22.4. Right to Non-Discrimination

You may exercise your rights under the CCPA without discrimination. For example, unless the CCPA provides an exception, we will not: 

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services;
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services;
  • Retaliate against an employee, application for employment, or independent contractor; or
  • Degrade your experience on our website.

22.5. Requirements for CCPA Verified Requests

In order to exercise certain rights under the CCPA below, you must include a “Verified Request.” The Verified Request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Such verification process will involve you confirming details of the personal information we have collected about you. In some instances, you may be required to submit proof of your identity (e.g., a driver’s license); and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

22.6. Opt Out of Certain Disclosures to Third Parties

You may opt out of “sales” of personal information and “sharing” of personal information for purposes of cross-context behavioral advertising by emailing “support@jantsons.com” with the subject line “CCPA opt out of third party disclosure,” with a description within of the specific categories of third party sharing form which you wish to opt out, and information that complies with the “Requirements for CCPA Verified Requests” section of this Policy.

22.7. Authorized Agent

You may also authorize an agent to exercise your rights on your behalf. To do this, you must provide the authorized agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from the agent when they make a request on your behalf. We may also ask you to verify your own identity and directly confirm with you that you have granted permission to the authorized agent.

22.8. Right to Request Deletion of Personal Information

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers or contractors to:

  • Complete a transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate to those purposes;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; and/or
  • Comply with a legal obligation.

If none of the above retention conditions apply, we will delete your personal information from our records and direct our service providers to do the same. 

To make such a request, email “support@jantsons.com” with the subject line “CCPA Request Deletion of Personal information,” along with details of which information you would like deleted and information that complies with the “Requirements for CCPA Verified Requests” section of this Policy.

22.9. Right to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate personal information that we maintain about you. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will use commercially reasonable efforts to correct inaccurate personal information, as directed. 

To do so, email “support@jantsons.com” with the subject line “CCPA Right to Correct Inaccurate Personal Information,” with a detailed description of what you would like corrected and information that complies with the “Requirements for CCPA Verified Requests” section of this Policy.

22.10. Right to Know What Personal Information is Being Collected, Sold, Shared, and to Whom; Right to Access or Request Disclosure of Personal Information

You have the right to request that we disclose certain information regarding our business practices with respect to personal information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

  • The categories of personal information we have collected or shared about you.
  • The categories of sources for the personal information we have collected about you.
  • Our business or commercial purpose for collecting or sharing that personal information.
  • The categories of third parties to whom we disclose or with whom we share that personal information by category or categories of personal information for each category of third parties to whom the personal information was shared.
  • The specific pieces of personal information we collected about you.
  • If we disclosed your personal information to a third party for a business purpose, a list of the personal information types each recipient received and the category of third party type to whom it was disclosed.

To request the above information, email “support@jantsons.com” with the subject line “CCPA Right to Know,” and include a detailed description of which of the above categories of data you are requesting and information that complies with the “Requirements for CCPA Verified Requests” section of this Policy.

22.11. Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right, at any time, to request that we limit the use of your sensitive personal information that we maintain about you to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, in the event we use or disclose your sensitive personal information for any other purpose. As a result, we provide you with the option to limit the use and/or disclosure of your sensitive personal information. 

To do so, email “support@jantsons.com” with the subject line “Limit Use & Disclosure of Sensitive Personal Information,” and within the body contain a request to limit the use and/or disclosure of your sensitive personal information and information that complies with the “Requirements for CCPA Verified Requests” section of this Policy. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will use commercially reasonable efforts to limit the use of your sensitive personal information, as directed.