Website Privacy Policy

What this privacy policy covers

JOLT Digital Learning Partners, LLC(“JOLTDLP”, “we”, “us”, or “our”) takes the privacy of our employees, clients, business partners, and web and social media site visitors seriously. We work to maintain compliance with major privacy regulations, such as General Data Protection Regulation (GDPR). This privacy policy will cover the JOLTDLP website (“website”, “site”) and our marketing landing pages (“pages”, “marketing pages”).

1       Purpose and Scope

1.1       Purpose

This policy covers how JOLTDLP uses personal information that the www.joltdlp.com website collects and how it is processed. Personal information is information that can be directly or indirectly personally identifiable, such as your name, address, email address, phone number, identification number, location data, etc., that is not otherwise publicly available.

1.2       Scope

This policy applies to the personal data of individuals that are previous, current, or prospective customers of JOLTDLP as well as any site visitors. This includes any personal data collected, used, or disclosed while visiting or using JOLTDLP’s website. Throughout your relationship with JOLTDLP, please keep us updated of any changes to your personal data, as it is important that any stored information remains up-to-date and accurate. If you have any changes to your personal data, would like to request the information that is stored, or have any questions or complaints regarding our site, please send your request to privacy@joltdlp.com and your request will be processed.

Any revisions made to this privacy policy, to meet any legal or regulatory obligations, will be communicated to our users via announcement banners on the site and will go into effect from the moment of communication. These types of revisions do not include changes to how your personal information is collected, used, or distributed. Any revisions regarding your personal data storage, use, or distribution will be communicated via email and will require your acknowledgment and consent.

The JOLTDLP websites are not intended for minors, and we do not knowingly collect personal data from, or relating to, minors. If you are the parent or guardian of a minor and believe they have provided us personal information and would like it removed, please contact us at privacy@joltdlp.com and we will dispose of the minor’s information from our system.

2       Information collection and use

2.1       What information is collected

JOLTDLP may collect limited amounts of personal information from site visitors, such as name, phone number, and email address, if that information is voluntarily provided by the visitor when accessing our website, online services, or contacting us on our website. Additionally, public IP address and User Agent (browser make/model + some other environment info) may be inadvertently collected as they are linked with your session.

2.2       How your personal information is used

Personal information collected from the website is stored and used in a limited capacity and with legitimate reasons. As stated in section 3 of this policy, JOLTDLP stores the following:

·       Name

·       Email

·       Phone number

·       IP address

·       Clicks on non-local <a>tags

·       Pageviews (main document loads)

When contact information is willingly provided through opt-in mechanisms, this information is used only in the following ways:

·       Enrollment in email campaigns with relevant messaging

·       Delivery of requested information or materials

·       Contact details to schedule follow-up discussions, when requested

Users have the option to opt out of JOLTDLP’s email communications as well as the right to request their contact information removed from our storage system or anonymized.

2.3       How information is shared or disclosed

JOLTDLP does not rent, sell, or share personal information about you with other individuals or non-affiliated companies or entities except to provide products or services you have requested. We provide the information to trusted partners who work on behalf of or with JOLTDLP under confidentiality agreements. These companies may use your personal information to do the following:

•       Help JOLTDLP with service delivery.

•       Help deliver our newsletter via email.

However, these companies do not have any independent right to share this information. We respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights defend against legal claims.

We may transfer information about you if JOLTDLP is acquired by or merged with another company. In this event, JOLTDLP will notify you before any personal information is transferred and becomes subject to a different privacy policy.

2.4       Confidentiality and security

The only JOLTDLP employees that will be granted access to your personal information are those who reasonably need to access that information to provide products or services to you or in order to do their jobs. These employees undergo security and privacy training prior to involvement with client information and stay up to date on current privacy and security regulations through recurring training. We have physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information.

2.5       3rd-Party Technology Use

JOLTDLP uses a third-party website content administrator and utilizes customer relationship management (CRM) database technology hosted by a third party to manage and track our marketing efforts.

3       Cookie Policy

This cookie policy (“Policy”) explains how JoltDigital Learning Partners, LLC (“JOLTDLP”, “we”, “us” and “our”) uses cookies and similar technologies (like web beacons) when you visit any of our websites that link to this Cookie Policy (such as www.JOLTDLP.com)("Websites").

It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and similar technologies to collect Personal Information or information that becomes Personal Information if we combine it with other information. In such cases, the JOLTDLP Privacy Policy will also apply.

3.1       What cookies are

A cookie is a small software file stored temporarily or placed on your computer’s hard drive. The main purpose of a cookie is to allow a web server to identify a user’s computer and web browser and tailor web pages and/or login information to a user’s preferences. Cookies help us promptly display the information needed to use the capabilities of the Service and other information which we consider to be of interest to visitors to the sites and users of the Service. By gathering and remembering information about website preferences through cookies, we can provide a better web and marketing experience. Cookies do not give us access to your computer.

3.2       The types of cookies JOLTDLPuses

There are two types of cookies: session cookies and persistent cookies. We use both session and persistent cookies. Session cookies allow us to uniquely identify your browser while you are logged in and to process your online transactions. Session cookies disappear from your computer when the web browser is closed or computer is turned off. We also utilize persistent cookies to make it easier to log into and use the Service. Persistent cookies remain on computers after the web browser is closed or the computer is turned off.

3.3       Third-party cookies

Cookies set by us are called"first-party cookies," while cookies set by others are called"third-party cookies." A third-party cookie can recognize your device both when it visits our Services and when it visits certain other websites or mobile apps. JOLTDLP does not control how third-party cookies are used, so you should check the website of a third-party cookie provider for more information about how they are used.

Both first-party and third-party cookies can serve many functions, including analytics, marketing, and advertising. For more information about how you can control advertising or analytics cookies, please see the relevant section below.

We do not track or respond to browser “Do not Track” requests.

3.4       Cookies and your PERSONAL INFORMATION

Some cookies are associated with your account and Personal Information, while others are not. We generally treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered Personal Information by local law, we also treat these identifiers as Personal Information. If we combine non-Personal Information with Personal Information, then the combined information will be treated as Personal Information for as long as it remains combined.

3.5       Why JOLTDLP uses cookies AND SIMILAR tracking technologies

JOLTDLP uses cookies and similar tracking technologies to enable functionality on its Services, and to assist with marketing its products and services to interested individuals. Cookies help us improve by telling us our Services are being used, letting you navigate between pages efficiently, remembering your preferences, and overall ensuring you enjoy your browsing experience on our Services.

The chart below explains how we generally use cookies.

JOLTDLP

Purpose

To  temporarily store user information to provide better service

When Expires

1 year

Cookie Source

1st  Party

Google Analytics

Purpose

To  track the traffic of our website

When Expires

24  months

Cookie Source

3rd  Party: https://policies.google.com/privacy

HubSpot

Purpose

To remember the preferences when users revisit a site page.

When Expires

12-120  months

Cookie Source

3rd  Party: https://knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser

3.6       Managing first-party COOKIES WITH your browser settings

If you would like to control the first-party cookies on our Services, you can use your browser to enable, disable, or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help,” “Tools,” or “Edit” settings). However, please be aware that if you set your browser to disable cookies, you may not be able to access secure areas of the Services and other parts of the Services may also not work properly.

Many browser manufacturers provide helpful information about cookie management, including, but not limited to:

·       Google Chrome

·       MozillaFirefox

·       Safari (Desktop)or Safari (Mobile)

·       Android Browser

·       Opera

·       Internet Explorer

If you use a different browser, please refer to your browser’s documentation. You can also find out more about how to change your browser cookie settings at www.allaboutcookies.org.

3.7       Use of log files

JOLTDLP gathers certain information automatically and stores it in log files. This information includes an anonymized internet protocol address as well as browser, internet service provider, referring/exit pages, search terms, operating system, date/time stamp, and clickstream data. Otherwise, we generally use this information as we would any Usage Data, to analyze trends, administer and maintain the Service, or track usage of various features within the Services.

3.8       JOLTDLP's use of clear GIFs/WEB BEACONS

When you use the Service, we may employ clear GIFs (also known as web beacons) which are used to track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service

3.9 Changes to JOLTDLP's Cookie Policy

We may, in our sole discretion, modify or update this Policy from time to time. If we make any material changes to this Policy, we will endeavor to notify you by email or by posting a prominent notice on the Sites prior to the change becoming effective, but will not be liable for any failure to do so. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Service constitutes your acceptance to be bound by such changes to this policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Service.

4       Privacy rights and compliance

4.1       Privacy rights

•       The right to access – You have the right to request copies of your personal data from our company.

•       The right to rectification – You have the right to request that our company corrects any information you believe is inaccurate. You also have the right to request our company to complete the information you believe is incomplete.

•       The right to erasure – You have the right to request that our company erases your personal data, under certain conditions.

•       The right to restrict processing – You have the right to request that our company restricts the processing of your personal data, under certain conditions.

•       The right to object to processing – You have the right to object to our company’s processing of your personal data, under certain conditions.

•       The right to data portability – You have the right to request that our company transfers the data that we have collected to another organization, or directly to you, under certain conditions.

Additionally, you may request for your information to be transferred to another organization if you wish to switch vendors. Please be aware that under no circumstances will a user be discriminated against for exercising any of these rights.

Please contact us at privacy@joltdlp.com if you would like to exercise any of these rights, opt-out of data processing, or have a question regarding the handling of your personal data. Our processing of your request may take up to one calendar month.

It is important to note that if processing is restricted, JOLTDLP may not be able to provide access to services.

4.2       Change in processing

If personal information is processed in a manner not laid out in this privacy policy, JOLTDLP will notify users and site visitors prior and provide them with the following information:

·       What information is to be processed

·       The legitimate purpose and interest of processing

·       Description of any data recipients

·       Duration of data storage and/or the criteria behind it

·       The right to file a complaint with their regions data protection authority, and how to exercise the rights of data access, deletion, correction, objection, and consent withdrawal

·       Any legitimate obligations to provide the information and, if applicable, the consequences of withholding the data

·       If data processing is automated and the logic and consequences for the user resulting from processing

After a user has received notice, the processing will not take place until clear, concise, and unambiguous consent has been provided by the user to opt-in to processing.

4.3       Compliance grievances

If you would like to put forward a complaint about how your information is processed, please contact us at privacy@joltdlp.com.

If your complaint regarding the processing of personal data cannot be handled internally, JOLTDLP will cooperate with the proper authority for your region to ensure your complaint is addressed.

4.4       Security breach protocol

JOLTDLP will notify the relevant authorities within 72 hours from when we are made aware of a security breach. Users will also be notified if there is ever any risk of your information being compromised.

4.5       Compliance audit procedure

To ensure continuous compliance with privacy laws and regulations, we perform annual audits on all security, risk, and privacy policies and practices.

4.6       Record keeping

JOLTDLP will keep up-to-date records of:

·       Audit reports

·       Policy adjustments

·       Purpose of data processing

·       Documentation on sec in place for the protection of personal data

This documentation regarding security practices performed by JOLTDLP can be provided to the proper authorities upon request.

5       Changes to this policy

JOLTDLP will continue to update this policy in an effort to keep user data as secure as possible. We will make updates by posting the revised policy to our website. You will be notified if there is ever any change in how your private information is handled. This policy was last updated June 10, 2022.

6       Questions and suggestions

If you have questions, suggestions, or wish to make a complaint, please complete a feedback form or you can contact us at:

JOLT Digital Learning Partners

5401 S. Kirkman Rd #310

Orlando Florida 32819

privacy@joltdlp.com