California Consumer Privacy Policy

This California Consumer Privacy Notice (“Notice”) supplements other JACS Solutions privacy policies and notices. If there is a conflict between any other JACS Solutions policy, statement, or notice and this Notice, this Notice will prevail as to California residents and their rights under California law.

The California Consumer Privacy Act (“CCPA”)

In accordance with the CCPA’s requirements, this Notice describes our collection, use, and disclosure of California consumers’ “Personal Information” (“PI”) during the preceding 12 months as well as the rights California consumers have under the CCPA. Defined terms in the CCPA used in this Notice have the same meanings as in the CCPA.
Collection and Use of Personal Information

Categories of PI Collected and Disclosed

Based on our practices in the past year, JACS Solutions collects PI directly from you, your devices, and your Internet browsers, including from your interactions with our website and advertisements, when you visit our website. We also collect PI from our vendors. We collect and disclose PI about California consumers as described in the table below.

Internet Usage Information

• Examples of PI Collected: Browsing history, search history, information regarding interactions with our website or advertisements
• Categories of Recipients: Service providers, ad networks, analytics providers, operating systems and platforms, social networks

Inferences from PI Collected

• Examples of PI Collected: Profiles reflecting preferences and predispositions
• Categories of Recipients: Service providers; clients

We may collect PI both directly from a consumer (for example, when you request information or assistance from us) and indirectly (for example, through user activity on our website). We also collect the PI of California consumers in our capacity as a service provider to our clients, and our clients may use our services to store PI on systems they control.

We collect PI for the following business purposes:

• Providing our products and services, including communications with you, verifying your information, marketing and advertising, analytics services, and other related services
• Detecting security incidents and protecting against malicious, deceptive, or unlawful activity
• Troubleshooting our services to identify and repair issues
• Internal research and development
• Quality and safety assurance
• Improving, upgrading, and enhancing our products and services
• Processing and managing interactions and transactions for our products and services

In addition, we may collect, use, and disclose your PI as required or permitted by applicable law, when requested or compelled by law enforcement or legal process, or in connection with contractual obligations.

Subject to the CCPA’s restrictions and obligations, our service providers, clients, and affiliates also may use your PI for some or all of the above-listed business purposes (including to facilitate interest-based advertising and other advertising and marketing).

California Privacy Rights

Under the CCPA, California residents have certain rights which they may exercise independently or through an authorized agent. CCPA rights requests are subject to an identification and verification process. We will not fulfill a CCPA rights request unless we have sufficient information to verify with reasonable certainty that the requestor is the consumer about whom we collected PI. Please note that these rights do not apply to us when we are acting as a service provider to our clients.

If we cannot comply with a request, we will explain the reasons in our response. We will use PI provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also provided the PI to us for another purpose.

Your California consumer privacy rights are described below. To make a request, you may email us at info@jacs-solutions.com or call us at 1-443-718-4333. When making a request, you will need to verify that you are the authorized user of the email or account information and that you are a current resident of the State of California. If you request that we provide you with specific pieces of information about you, we will apply heightened verification standards.

An authorized agent may submit a request on behalf of a consumer if the consumer has provided the authorized agent with power of attorney in accordance with California law; alternatively, JACS Solutions will (1) require the authorized agent to present verifiable written authorization from the consumer that the authorized agent has the consumer’s permission to submit the request; and (2) independently verify the consumer’s own identity with JACS Solutions.

We will not discriminate against you for exercising your CCPA rights.

Disclosure Rights

You have the right to request that we disclose the following information about your PI that we maintain and that we have collected in the 12-month period prior to your request date. Requests of this nature may be made no more than twice in a 12-month period.

• The categories of PI we have collected about you
• The categories of sources from which we collected your PI
• The business or commercial purposes for collecting or selling your PI
• The categories of third parties with whom we have shared your PI
• The specific pieces of PI we have collected about you
• A list of the categories of PI disclosed for a business purpose in the prior 12 months (or that no disclosure occurred)
• A list of the categories of PI sold about you in the prior 12 months (or that no sale occurred)

You also have the right to make or obtain a copy of your PI that we maintain and that we have collected in the period that is 12 months prior to the request date.

“Do Not Sell” Rights

We do not sell California consumer PI as defined under the CCPA, including PI of minors under the age of 16, as the term “sell” is defined under the CCPA. We do work with service providers and may partner with advertising companies that use cookies and other tracking technologies to collect information about your visits to our website and third-party websites, and then use that information to deliver advertisements relevant to your interests. For more information on how we use cookies and other tracking technologies, and your choices about our use of these technologies, please review the “Information Collected Automatically” portion of our Privacy Policy.

Deletion Rights

Except to the extent we have a basis for retention under the CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include to complete transactions and provide services you have requested or that are reasonably expected; for security purposes; for legitimate internal business purposes, including maintaining business records; to comply with law; to exercise or defend legal claims; and to cooperate with law enforcement and other public authorities.

California’s “Shine The Light” Law

California’s “Shine the Light” law permits customers in California to request certain details about how some types of their information are shared with third parties and, in some cases, affiliates, if that information is shared for those third parties’ and affiliates’ own direct marketing purposes. We do not share your information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes.

If you are a California resident, you may request information about our compliance with this law by contacting us at info@jacs-solutions.com or by sending a letter to the Director of Finance, JACS Solutions, Inc., 809 Pinnacle Drive, Suite R, Linthicum Heights, MD 21090. Requests must include “California Shine the Light Privacy Rights Request” in the first line of the description and identify your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one such request per customer annually.
California “Shine the Light” rights and CCPA rights are established under different legal regimes and must be exercised separately.

Contact Us

For questions about this California Consumer Privacy Notice, you may contact us at 1-443-718-4333 or by email at info@jacs-solutions.com. You also may write to us at:

JACS Solutions, Inc.
(Attn: Director of Finance)
809 Pinnacle Drive, Suite R
Linthicum Heights, MD 21090

Effective Date: January 1, 2022