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Privacy Policy/CCPA Notice

Effective Date: August 1, 2025

Last reviewed: August 31, 2025

 

SCOPE AND OVERVIEW

Jenne, Inc. (“Jenne”) respects your privacy and is committed to protecting the security of our customers, prospective customers, and other individuals in connection with our distribution services and commercial financing programs.   Your personal information will be processed fairly and lawfully and will be protected against unauthorized access and processed using appropriate technical and organizational security measures and controls.

This Privacy Policy describes the categories of personal information that we collect, how we use your personal information, how we secure your personal information, and when we may disclose your personal information to third parties. Your personal information will be collected, used, stored, processed and transmitted by Jenne, in accordance with its established policies and applicable federal, state, local and international laws, rules and regulations.

Jenne is a technology distributor headquartered in Avon, Ohio. Jenne provides distribution and other supply chain services to Resellers to support hardware, software, security and cloud service offerings. These services include logistics, financing, training, marketing, design and provisioning.

Jenne provides Resellers and other Business Partners with the ability to purchase or access a variety of products and services made available through our Vendors.  JENNE IS CONTRACTUALLY OBLIGATED TO PROCESS INFORMATION ON THE VENDOR’S BEHALF, INCLUDING SOME PERSONAL INFORMATION. EACH PRODUCT OR SERVICE WILL BE SUBJECT TO THE VENDORS PRIVACY POLICIES AND CONTRACTUAL AGREEMENTS WITH YOU, WHICH MAY SUPERCEDE OR COMPLEMENT THE TERMS OF THIS PRIVACY POLICY. JENNE ENCOURAGES YOU TO READ THE PRIVACY POLICIES OF EACH VENDOR THAT YOU ARE, OR ARE CONSIDERING, DOING BUSINESS WITH ALONG WITH ANY AGREEMENTS THAT YOU MAY HAVE WITH ANY OF OUR VENDORS BEFORE ACCESSING OR USING THEIR PRODUCTS OR SERVICES.

Although we encourage you to read our entire Privacy Policy, below is a summary of some of the more important aspects of the Privacy Statement:

  • We may collect both personal information and other information from you through a variety of sources, including personal information that we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as affiliates, publicly available information sources (including information from your publicly available social media profiles or other digital platforms), and other third parties.
  • We will not use or share your personal information except as described in this Privacy Statement.
  • Where applicable, we honor opt out instructions from you for certain uses of your personal information under this Privacy Statement, such as, for example, when you opt out of receiving marketing email communications from us.
  • We use appropriate technical and organizational controls to secure and protect your personal information, but we cannot ensure or warrant that your personal information will be completely secure from misappropriation by hackers or from other nefarious or criminal activities.

It is important that you read this Privacy Policy, together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your information.

PLEASE NOTE FURTHER:  Our services and website are designed for business customers and we do not knowingly collect personal information from individuals under 18 years of age. If we discover that we have collected information from a minor, we will promptly delete such information.

THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

Jenne may collect personal information about you from a variety of sources, including, directly from you, from other users, from resellers, from our vendors, from our service providers, from third-party information providers, from our affiliates, and through the operation of the Website and other services.

“Personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or de-identified information).

Jenne may collect, use, store, and transfer different kinds of personal information about you which we have grouped together as follows:

  • Identity Information such as first name, last name, username or similar identifier, title, company name, and government issued identification number.
  • Contact Information such as billing address, shipping address, email address and telephone numbers.
  • Financial Information such as bank account, business financial statements, asset and liability information, payment card details and credit history.
  • Transaction Information such as details about payments to and from you and other details of products and services you have purchased from us, including account activity and usage patterns.
  • Technical Information such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website.
  • Profile Information such as your username and password to access our Website, account number, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data such as information about how you use our Website, products and services.
  • Preference Data such as your preferences in receiving marketing from us and our third parties, and your communication preferences.
  • Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Applicant Information such as your email address, employment history, resume or other professional information, education history, answers to job application questions and any other requested information, testing results, background checks, and professional certificates that you submit to us during the job application process.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature. However, if we do combine or connect aggregated data with your personal information, so that it can directly or indirectly identify you, then we will treat the combined data as personal information which will be used in accordance with this Privacy Policy.

Sensitive Information – Unless Jenne specifically requests or invites you to provide sensitive personal information, we ask that you not send us through this Website or otherwise disclose any information related to your race, gender or ethnic origin, political or religious beliefs, health, criminal background. If we do request or invite you to provide sensitive personal information, we will do so with your express consent.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

Directly from You

We may collect personal information directly from you when you voluntarily provide it to us. For example, when you communicate with us over the telephone or through our Website by way of email, web form, or online account registration to create an account, obtain access to our products and services, place an order for our products or services, register for an event or training, visit our booth at a trade show, enter an incentive program, promotion or survey, ask questions, give us feedback, attempt to resolve any issues related to our Website or any of our products and services, submit a job application, or submit feedback and comments. We will also keep details of transactions you carry out through our Website and of the fulfillment of your orders, as well as records and copies of your correspondence (including email addresses), if you contact us. You may also be required to provide financial information before placing an order through our Website.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

Please note, it is your responsibility to provide Jenne with accurate personal information. Additionally, the failure to provide us with your personal information may interfere with our ability to conduct business with you, such as purchasing products and services or processing your transactions.

Automatically through Your Use of Our Website or Services

When you visit our Website, we may monitor and collect information about how you access, use, and interact with our Website automatically through “cookies,” “flash cookies”, “web beacons,” and other automated tracking technology. (See, the Cookies and Other Similar Technologies section below) For example, we may automatically collect technical data about your equipment, browsing actions and patterns such as your IP address, device type, unique device identification numbers, browser-type, operating system, your Media Access Control (MAC) Address, Website usage analytics and cookies, broad geolocation data (e.g. country or city-level location(when permitted)) and other technical information.

From Other Sources

From Resellers. We may obtain personal information about you from the resellers that purchase products and services available from us and provide such products and services to you.

From Our Vendors. We may obtain personal information about you from the third-party vendors that make products and services available through us.

From Third-Party Service and Information Providers. Jenne may also obtain personal information from third parties that have obtained or collected information about you and that have the right to provide that personal information to us. For example, we may contract with third parties that are in the business of providing information to businesses such as ours to verify certain information about you or obtain information. We may use the personal information about you that we receive from a third-party outside of our Website in accordance with the terms we establish with that third-party. We may also obtain personal information at trade shows or events where you have attended and provided your consent to collect your personal information and from publicly-available sources such as open government databases or other information in the public domain.

Cameras and Telephones. Additionally, we may obtain your personal information from the CCTV cameras located in the offices and warehouses of the Jenne companies and from recordings of telephone calls. The purpose of the video and phone recordings is the protection of our property, prevention and detection of criminal activity and the protection of health and life of our employees/clients.

Jenne takes reasonable steps to ensure that the personal information that we collect about you is adequate, relevant, and processed for limited purposes.

Automated Decision-Making and Profiling. We may use automated decision making-making technology (ADMT) for:

  • Credit and Risk Assessment:  Evaluating creditworthiness and loan applications using algorithms that analyze financial data credit history, and risk factors.
  • Fraud Detection: Automated systems to identify potentially fraudulent transactions or applications
  • Pricing and Terms: Determining financing terms, interest rates, and credit limits based on automated risk models
  • Account Management: Automated decisions regarding account limits, payment schedules, and collection activities

ADMT Safeguards:

  • Human oversight and review capabilities for significant decisions
  • Regular algorithm auditing for bias and accuracy
  • Transparency regarding the logic and factors used in automated decision-making
  • Consumer rights to opt-out and request human review (where legally required)

Significant Decisions: We consider the following as significant decisions under California law:

  • Approval or denial of credit applications
  • Determination of credit limits or financing terms
  • Account suspension or termination decisions
  • Collection and recovery actions
  • Complying with applicable laws and regulations
  • Responding to legal requests and court orders
  • Protecting against fraud, security threats, and illegal activities
  • Enforcing our terms of service and contractual agreements

HOW WE WILL USE YOUR PERSONAL INFORMATION

Jenne uses personal information we collect about you to operate our business and provide you with products and services, which includes using this information to improve our offerings and personalize your experiences. We also may use the information to communicate with you, for example, informing you about your account and product information.

We will only use your personal information when the law allows us or with your consent. Most commonly, we will use your personal information in the following circumstances:

  • To present our Website and its contents to you and maintain, enhance, and improve our Website and our products and services, including to operate certain features and functionality of our Website;
  • To manage our day-to-day business needs such as registering you as a new customer and delivering relevant website content, sending advertisements and other communications about our products, services, and events that we believe may be of interest to you, notifying you about changes to our Website or any products or services that we offer or provide though it, and to measure and better understand user preferences and the effectiveness of the advertising we serve to you, in accordance with applicable law or based on your marketing preferences to enhance user experience (See the Marketing Preferences section below);
  • To manage our relationship with you including sending welcome letters, newsletters, surveys, promotions and other special offers in accordance with your marketing preferences, to verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes as well as providing billing reminders, technical notifications and security announcements; responding to your inquiries; fulfilling your requests, discussing issues related to your account, providing you with effective customer support, and keeping our records updated;
  • To provide you with information regarding the status of your account, to determine your tax status, and process and deliver your order including managing billing, payments, fees, and charges for our products and services;
  • To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you including but not limited to, informing Jenne’s marketing strategy, troubleshooting, testing and audits, data analysis, system maintenance, reporting and hosting of data, identifying usage trends, and operating and expanding our business activities, as well as to personalize our products and services, provide you with tailored content, conduct business analytics, and otherwise improve the security and performance of our products and services, along with any other lawful purposes.
  • To Vendors and Resellers in connection with the provision of the services or support of Jenne's business. For example, Jenne may use your personal information to measure service usage and service performance metrics; monitor security aspects of our Services and infrastructure; provide data storage services; and deliver technical support. Jenne will only release information that is needed to deliver the service for which the third-party vendor has been retained. These vendors are required to maintain strict security and confidentiality of the information and are prohibited from using it for any other purposes other than in accordance with applicable federal state and local laws and regulations.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including to enforce compliance with our Terms and Conditions, for billing and collection purposes; and to prosecute and/or defend a court, arbitration or similar legal proceedings;
  • To comply with a legal or regulatory obligation or respond to lawful requests by credit reference agencies, fraud prevention agencies and public authorities (including national security and other law enforcement agencies);
  • To reorganize, restructure, or dispose of all or a portion of our business assets (including in connection with any bankruptcy or other proceeding), provided that the use of your personal information by that third party remains subject to applicable law;
  • To process job applications;
  • For any other purpose with your consent.

We may also process your personal information:

  • To monitor and prevent fraud; and
  • To administer IT services, ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.

We may combine and enhance the personal information we collect about you with other information we receive from third parties.

We may also use the personal information we collect about you through our Website to generate anonymized, aggregated data. When we do so, we ensure that the anonymized, aggregated data is no longer personally identifiable and may not later be used to identify you. This will include, by way of example, storing the anonymized, aggregated data separately from any personal information.

If Jenne does engage in the processing of your personal information for purposes other than those specified in this Privacy Policy, we will, where appropriate, provide you with notice of these changes, including the purposes for which the personal information will be used, and the recipients of the personal information.

Please note that we do not generally rely on consent as a legal basis for processing your personal information and we may process your personal information without your knowledge or consent, in compliance with the above rules, and where it is required or permitted by law.

For example, we may access and use information from credit reference agencies when you open your account and periodically to:

  • Manage and make decisions about your account, including assessing your creditworthiness;
  • Check your identity and verify the accuracy of the personal information that you provide to us;
  • Prevent fraud and other criminal activity; and
  • Trace debtors and recover debts.
  • Make application decisions, which may be made based solely on automated checks of information from credit reference agencies and internal records.

If we, or a fraud prevention or other law enforcement agency, determine that you pose a fraud or other criminal risk, we may refuse to provide services to you.

Please Note Further: The provision of certain categories of your personal information may be required to enter into a contract with Jenne. If required personal information is not provided, you will not be able to open a user account and/or use our products and services.

MARKETING PREFERENCES

Jenne may use your personal information for direct marketing purposes. You have the right, at any time, to refuse to allow your personal information (email address, telephone number) to be used for this purpose or withdraw your consent, if applicable. If you do not want your personal information to be used for this purpose, please update your preferences. You may Opt-Out of marketing emails by clicking the link at the bottom of any of our emails, or you may submit your request to us at privacy@jenne.com.

HOW WE MAY SHARE YOUR PERSONAL INFORMATION

We may share your personal information with your consent or as necessary to complete any transaction or provide any products and services that you have requested or authorized. We also share personal information with third-party vendors, resellers, service providers, affiliates and other business partners, when required by contract and/or law, to respond to legal process, to protect our customers, to protect lives, to maintain the security of our offerings, and to protect the rights or property of Jenne.

We may disclose personal information that we collect or you provide as described in this privacy policy, as follows:

Vendors. Jenne may share personal information about you with the third-party vendors that make products and services available through us. For example, we may share your personal information with a third-party vendor if you purchase or access a product or service through us, or a Jenne reseller, and that vendor requires verification of a purchase in order to register that product or service. We may also share your personal information with a third-party vendor if that vendor co-sponsors a marketing activity with us to verify your participation in the marketing activity.

Resellers. Jenne may share your personal information with resellers that purchase products and services available through our Website. For example, we may share your personal information if you purchase or access a product or service through a reseller, and that reseller leveraged our reseller tools and services.

Third-party Service Providers. Jenne may provide your personal information to third-parties that provide services to assist us with our Website and with achieving our business purposes. For example, these third parties may include providers of customer service, payment processing, email and messaging support, hosting, management, maintenance, data analysis, marketing research, offering fulfillment or delivery, recruiting, providing background and other reference checks, or other services we may receive on an outsourced basis.  Our third party service providers are subject to:

  • Comprehensive due diligence and security assessments
  • Contractual obligations to protect your information
  • Regular security audits and compliance monitoring reports
  • Strict data processing and retention limitations

Encrypted Technology for Sensitive Data

For the most sensitive personal information, including:

  • Social Security Numbers and Tax ID Numbers
  • Bank Account and routing numbers
  • Credit pard and payment information
  • Detailed financial statements

We utilize vetted third-party service providers that employ:

  • Advanced Encryption Standards (AES-256) for data at rest
  • Transport Layer Security (TLS 1.3) for data in transit
  • Zero-knowledge architecture where technically feasible
  • Multi-factor authentication and access controls
  • Regular penetration testing and vulnerability assessments

Types of Third-Party Providers

Our service providers may include:

  • Credit reporting agencies and financial institutions
  • Payment processors and banking partners
  • Cloud storage and computing services
  • Identity verification and fraud prevention services
  • Customer relationship management (CRM) platforms

Contractors, Affiliates and Other Business Partners. Jenne may share your personal information with our Contractors, Affiliates, and Partners, regardless of whether these entities share the Jenne brand. Our Contractors, Affiliates, and Partners will use your personal information we share with them in a manner consistent with this Privacy Policy.

Other Users. Jenne may share your personal information with other users when you elect to interact with those users (or request that we communicate with them on your behalf) through our Website. This may include facilitating communications with other Vendors and other users.

Law Enforcement and Safety. Jenne may share your personal information with any competent law enforcement, regulatory, government agency, court, other governmental officials, or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, (iii) to protect your vital interests or those of any other person, (iv) to protect our operations or the rights, privacy, property or safety of Jenne, our customers, or others, or (v) to allow us to pursue available remedies or limit the damages that we may sustain.

Professional Advisors and other Agents and Representatives. Jenne may share your personal information with professional advisers and other agents and representatives acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Sale or Acquisition of Assets. If Jenne transfers ownership or control of any portion of Jenne or our Website to an actual or potential buyer, whether in the context of an acquisition, merger, reorganization, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer your personal information to that actual or potential buyer, provided that the use of your personal information by that third-party remains subject to applicable law.

Others. We may share your personal information with any other person with your consent to the disclosure or to otherwise fulfill the purpose for which you provided it or any other purpose disclosed by us when you provided the personal information.

Aggregated Data. We may also share aggregated, anonymized data with third parties for other purposes. Such data does not identify you individually, but may include usage, viewing and technical information we collected through your use of our Website. If we are required under applicable law to treat such information as personal information, then we will only disclose it as described above.

Jenne does not sell your personal information to third parties. We may, however, disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Jenne takes reasonable measures to ensure that our third-party service providers only process your personal information for specified purposes and in accordance with our instructions and all applicable data protection laws.

COOKIES AND OTHER SIMILAR TECHNOLOGIES

Cookies and other similar technologies can provide us with tailored information while you visit our Website. You have the right to request that Jenne not contact you or use your personal information for purposes which are not reasonably necessary for the administration of our Websites and/or the provision of products and services.  

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). Cookies are data elements that a website can send to your browser and are stored on your system. Some website pages use cookies to better serve you when you return to our site. The site cookie sent to your address contains what country location you have selected and if you have selected on-line settings for visiting the site. The site does not store individual names, email addresses, street addresses, credit card numbers, or phone numbers in cookies placed on your computer. However, the site does collect non-identifiable information from visits to our site to help us provide better customer service. For example, we track the domains people visit and we measure visitor activity on the site, but we do so in ways that keep personal information non-identifiable. Jenne uses this data to analyze trends and statistics and to help us provide better customer service.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the Choices About How We Use and Disclose Your Personal Information section below.
  • Web Beacons. Pages of our Website [and our e-mails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages [or opened an email] and for other related website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL INFORMATION

We strive to provide you with choices regarding the personal information you provide to us, the steps you can take to access your information and to request that we change your personal information, where appropriate.  We will obtain your explicit consent before sharing information for purposes not covered by this Policy.

Cookies. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. In addition, the offerings we provide when you visit us may not be as relevant to you or tailored to your interests. You can also set your browser to alert you when cookies are being sent.

Flash Cookies. Aspects of our website may still use Flash cookies.  To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website.

However, please be aware that if you disable or reject cookies, some features and services of our Website may then be inaccessible or not function properly because we may not be able to recognize and associate you with your account(s).

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by emailing us at privacy@jenne.com or responding to an email from us stating your request.

Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by emailing us at privacy@jenne.com This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

Targeted Advertising. If you do not want us to use personal information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by emailing us at privacy@jenne.com.

Third Party Tracking. We do not control third parties' collection or use of your personal information or other information to serve interest-based advertising. Third parties use of cookies or these other tracking technologies is not covered by this Privacy Policy, however these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Please note that you cannot unsubscribe from certain correspondence from Jenne regarding our provision of products and services to you, including messages relating to your account, unless you stop using our products and services. In addition, certain information may be required in order to use our Website or products and services; as such, the only method for opting out of providing personal information in connection with the use of this Website or our products and services may be to refrain from subscribing to or using them.

Nevada Residents. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to privacy@jenne.com. However, please know that we do not currently sell any information that triggers that statute's opt-out requirements.

HOW DO WE ENSURE THE SECURITY OF YOUR DATA?

USE OF TECHNICAL SAFEGUARDS

Jenne uses appropriate technical and organization controls and measures to secure and protect your personal information from unauthorized loss, misuse, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.  

Jenne maintains a robust system to ensure the protection of all business data, including but not limited to, the following :

  • Encryption: All sensitive data encrypted using industry-standard protocols (AES-256 minimum)
  • Access Controls: Role-based access with principle of least privilege and multi-factor authentication
  • Network Security: Firewalls, intrusion detection, and continuous monitoring systems
  • Secure Transmission: All data transfers protected by TLS 1.3 or higher encryption protocols
  • Regular Updates: Security patches and system updates applied promptly
  • Vulnerability Management: Regular security assessments, penetration testing, and threat modeling
  • Zero Trust Architecture: Implementation of zero trust security principles where feasible

JENNE ADMINISTRATIVE SAFEGUARDS

In addition to technical and organizational controls, Jenne undertakes the following Administrative safeguards to ensure the protection of all business data, including but not limited to, the following:

  • Employee Training: Regular security awareness, privacy training, and CCPA compliance programs
  • Background Checks: Comprehensive screening for employees with data access
  • Data Handling Procedures: Documented processes for data collection, use, and disposal in compliance with CCPA requirements
  • Incident Response: Established procedures for security breach notification and response, including CPPA notification requirements
  • Data Protection Impact Assessments: Regular risk assessments as required by California regulations
  • Automated Decision-Making Governance: Policies and procedures governing the use of ADMT systems
  • Third-Party Management: Due diligence and ongoing monitoring of service providers

The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Cybersecurity Audits and Risk Assessments (California Requirements)

In compliance with new California regulations effective 2025:

Annual Cybersecurity Audits: (for businesses processing 10 million or more consumer personal information records annually)

  • Independent third-party cybersecurity audits conducted annually
  • Assessment of data security practices, controls, and incident response procedures
  • Documentation of audit findings and remediation efforts
  • Audit reports maintained for regulatory inspection

Data Protection Risk Assessments: (for businesses processing sensitive personal information of 100,000+ consumers)

  • Comprehensive annual risk assessments of data processing activities
  • Evaluation of cybersecurity safeguards and data handling practices
  • Assessment of third-party data processing arrangements
  • Documentation of risk mitigation strategies and implementation timelines

Physical Safeguards

  • Facility Security: Controlled access to data centers and offices
  • Equipment Protection: Secure storage and disposal of hardware containing data
  • Environmental Controls: Protection against natural disasters and physical threats

Jenne will notify you in the event we become aware of a security breach involving your personally identifiable information (as defined by the applicable foreign, federal, state, and local laws) stored by or for us, in accordance with applicable laws.

ACCESS TO YOUR PERSONAL INFORMATION

In accordance with applicable data privacy laws, you may be entitled to request certain information about the personal information we have stored about you; to request certain access to, correction, deletion, or portability of such information, and you may request restriction of processing or object to the processing by emailing us at privacy@jenne.com.

If you have any questions regarding the processing of your personal information or you need to update or change your personal data, you may log into your account, or contact your sales representative, contact us via email at privacy@jenne.com.

Jenne reserves the right to decline requests to access or delete personal information if and to the extent disclosure or deletion of the personal information requested is not required or permitted by applicable law.

To guard against fraudulent requests for access, Jenne reserves the right to verify your identity by requiring sufficient information to allow us to confirm the identity of the party making the request before granting access or making corrections.

COMPLIANCE WITH LOCAL LAWS 

This Privacy Policy is meant to guide Jenne with respect to personal information collected from or about you. While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to Jenne may require standards that are stricter than this Privacy Policy, and in such event, Jenne will comply with applicable local laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions.

General Privacy Rights (All Locations)

Depending on your location, you may also have the following rights:

Access and Portability:

  • Request copies of personal information we hold about you
  • Receive information in a portable, machine-readable format

Correction and Updates:

  • Request correction of inaccurate or incomplete information
  • Update your contact preferences and account details

Deletion and Restriction:

  • Request deletion of personal information (subject to legal requirements)
  • Limit processing for specific purposes

Marketing Communications:

  • Withdraw consent for marketing communications
  • Opt out of certain data sharing arrangements

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. You have the following rights under the California Consumer Privacy Act:

Right to Know:

  • Request specific pieces of personal information we have collected about you
  • Request categories of personal information collected, sources, business purposes, and third parties with whom we share information
  • Request information about our data retention periods

Right to Delete:

  • Request deletion of personal information we have collected (subject to legal and business exceptions)
  • We will honor deletion requests unless the information is necessary for specific business purposes or legal compliance

Right to Correct:

  • Request correction of inaccurate personal information
  • We will use commercially reasonable efforts to correct inaccurate information

Right to Opt-Out:

  • Sale and Sharing: Opt out of the sale or sharing of personal information for cross-context behavioral advertising
  • Sensitive Personal Information: Limit our use and disclosure of sensitive personal information to specific permitted purposes
  • Targeted Advertising: Opt out of targeted advertising based on personal information

Right to Non-Discrimination:

  • We will not discriminate against you for exercising your CCPA rights
  • We will not deny services, charge different prices, or provide different levels of service quality based on your exercise of rights

Right to Limit Sensitive Personal Information:

  • Request limitation of use and disclosure of sensitive personal information, including:
    • Social Security numbers and driver's license numbers
    • Account log-in credentials and financial account information
    • Precise geolocation data
    • Racial or ethnic origin, religious beliefs, or union membership
    • Contents of mail, email, and text messages (unless we are the intended recipient)
    • Genetic data and biometric information for identification purposes

Automated Decision-Making Technology (ADMT) Rights

Under California's new ADMT regulations (effective 2025), you have additional rights when we use automated decision-making technology that makes or is a substantial factor in making significant decisions about you:

Right to Opt-Out of ADMT:

  • You may opt out of our use of ADMT for significant decisions that produce legal effects or similarly significant effects concerning you
  • Significant decisions include those related to credit eligibility, loan approvals, and financing terms

Right to Access ADMT Information:

  • Request information about the logic involved in our automated decision-making
  • Understand the significance and envisioned consequences of such processing
  • Request human review of automated decisions when technically feasible

ADMT Notice Requirements:

  • We will provide clear notice when ADMT is used for significant decisions
  • Notice will include the categories of personal information used and the purpose of the automated decision-making

How to Exercise Your Rights

To exercise these rights, contact us using the methods provided in this Policy, we will:

  • Respond to requests within 45 days (with possible 45-day extension)
  • Verify your identity using reasonable methods
  • Provide information free of charge (up to twice per 12-month period)
  • Not charge a fee unless requests are excessive, repetitive, or manifestly unfounded

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time. It is our policy to notify you of any changes that we make to our privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. If we make material changes to how we treat our users' personal information we will communicate this to you through a notice on our Website home page.

If we need or are required to contact you concerning any issue or event that involves this Privacy Policy, then we will do so using the email address, telephone number, or physical mailing address we have on file for you.

You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Regulatory Compliance

This Policy is designed to comply with applicable privacy laws, including:

  • General Data Protection Regulation (GDPR)
  • California Consumer Privacy Act (CCPA)
  • Gramm-Leach-Bliley Act (GLBA)
  • Fair Credit Reporting Act (FCRA)
  • State and federal privacy regulations

Definitions

  • Personal Information: Any information that identifies, relates to, or could reasonably be linked to an individual or household.
  • Processing: Any operation performed on personal information, including collection, storage, use, disclosure, and deletion.
  • Sensitive Personal Information: Information requiring heightened protection, such as SSNs, financial account numbers, and precise geolocation data.
  • Third-Party Service Provider: External organizations that process personal information on our behalf under contractual agreements.

CONTACT US

If you have any questions or concerns about this Privacy Policy, the privacy practices of Jenne, our collection or use of your personal information, or you wish to access your personal information, please contact us at: privacy@jenne.com.