California Privacy Notice

California Privacy Notice
Effective Date: January 1, 2023
You can click on the following links to navigate to the different sections in this California Privacy Notice.

This California Privacy Notice (“CA Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (as amended, the “CCPA”) and supplements the JLM Systems, Inc and its affiliates and subsidiaries (“JLM Systems,” “we,” “us,” “The Company”) Privacy Policy https://www.throttleweb.com/privacy-policy. In the event of a conflict between any other JLM Systems policy, statement, or notice and this CA Notice, this CA Notice will prevail as to California Consumers and their rights under the CCPA. In accordance with the CCPA’s requirements, unless otherwise noted, the disclosures contained within this CA Notice cover our activities in the prior 12 months from the Effective Date, as well as our current practices, and describes our Collection, use, and disclosure of California Consumers’ Personal Information, as well as the rights California Consumers have under the CCPA. Capitalized terms defined in the CCPA that are used in this CA Notice have the same meanings as in the CCPA, and other defined terms herein have the same meanings as in our Privacy Policy https://www.throttleweb.com/en-gb/information/privacy.
This CA Notice applies to California Consumers that visit our Sites (as defined in our Privacy Policy https://www.throttleweb.com/en-gb/information/privacy) or use our services.
Personal Information We Collect And Why We Collect It
“Personal Information” means information that identifies, relates to, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household. Personal Information does not include information that is publicly available, Deidentified, or Aggregated Consumer Information.
We Collect Personal Information about California Consumers as described below. Note that the specific pieces of Personal Information we Collected about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.
Category of Personal Information

Identifiers: To respond to your requests; to create new member accounts at your request; to communicate with you for marketing and informational purposes; to provide you with the products and services you request from us pursuant to the terms of a sales contract; and to provide you with information about our products and services that you request from us.
Examples: Name, address, phone number, email address, date of birth, IP address, unique identifiers, and social security number in certain instances.

Personal Information described in Cal. Civ. Code § 1798.80(e): To process payments for products and services purchased on the Sites. We also use this information when we assist with financing when you apply for insurance or other financing.

Examples: Identifiers listed above, signature, or financial information.

Characteristics of Protected Classifications Under California or Federal Law: To provide you with certain products (including death certificates); to determine your product and service preferences; and in order to market products and services we think would be of interest to you.

Examples: Age, gender, ethnicity, religion, and veteran status.

Commercial Information / Purchase Details: To fulfill orders; to improve our service and merchandise offerings; to tailor our marketing efforts; to create records of consuming history for audit purposes; in order to fulfill the terms of pre-need and at-need funeral and cemetery contracts; and for internal reporting purposes.

Examples: Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or Other Electronic Network Activity Information: To securely deliver, troubleshoot, and improve services; to detect fraud; to provide relevant marketing; and for any other internal business purposes.

Examples: Browser type, browsing history, and information regarding interactions with our Sites.

Geolocation Data: To estimate an approximate location of the device you are using to access our Sites in order to enhance and personalize the features and functionality of our Sites, including our service offerings.

Examples: Your physical location based on information you provide directly or inferred from your IP address.

Audio, Electronic, Visual, or Similar Sensory Information: We may post this information to public areas of our Sites or to external sites at your direction. For example, we may live stream a funeral service on external sites at your direction.

Examples: Audio and video files and surveillance footage.

Inferences from other Personal Information We Collect: To provide you with appropriate products and recommendations for marketing and advertising, and for any other internal business purposes.

Examples: Your preferences based on other Personal Information collected about you.

Additional Types of Personal Information: To communicate with you about our products and services, your orders, updates to our terms and policies, and to obtain your feedback; to provide customer service and support; to improve our Sites, and to detect and prevent fraud against you and/or us, to determine the types of services you may need.

Examples: The contents of messages you submit to us through contact, sign-up, and purchase forms on the Sites, health data.

Subject to the CCPA’s restrictions and obligations, our business partners and Service Providers may also use your Personal Information for some or all of the above-listed Business Purposes.
Sources of Personal Information
We may Collect your Personal Information directly from you when you provide us personal information through the Sites; in person at one of our permanent locations or temporary locations; by phone; by mail; automatically through the Sites via cookies and other tracking technologies; or from our business partners. More detail on the ways in which we Collect Personal Information can be found in our Privacy Policy https://www.throttleweb.com/en-gb/information/privacy.
Disclosures of Personal Information
We disclose Personal Information to other entities in our corporate family, which includes our affiliates; business partners and Service Providers acting on our behalf that help us provide our services; or to other parties at your request. More information on how we disclose Personal Information can be found in the Selling and Sharing of Personal Information section below.
We disclose the following categories of Personal Information with our Service Providers and affiliates for a Business Purpose:

Identifiers
Personal Information described in Cal. Civ. Code § 1798.80(e)
Characteristics of Protected Classifications Under California or Federal Law
Commercial Information/Purchase Details
Internet or Other Electronic Network Activity Information
Geolocation Data
Audio, Electronic, Visual, or Similar Sensory Information
Inferences
Additional Types of Personal Information

In addition to the reasons for disclosure listed in the chart above, we may further disclose your Personal Information to comply with applicable law or respond to valid legal process, and to support our compliance with valid inquiries and directives from law enforcement or other government agencies. In addition, each of the above referenced categories of Personal Information may be disclosed as part of a corporate transaction or proceeding.
Retention of Personal Information
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we Collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes. To determine the appropriate retention period for Personal Information, we consider applicable legal requirements, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes we process your Personal Information for, and whether we can achieve those purposes through other means. For certain types of Personal Information, we will only maintain it for a limited duration. Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
Selling and Sharing of Personal Information
We may Sell to Third Parties or Share with Third Parties for Cross-Context Behavioral Advertising the below categories of Personal Information. We offer you the ability to opt-out of these disclosures as set forth in the “Your Opt-Out Rights” Section below.

Identifiers
Internet or Other Electronic Network Activity Information
Geolocation Data

We may Sell or Share these categories of Personal Information to our advertising partners for marketing and advertising purposes.
California Privacy Rights
California residents have the right to submit certain requests relating to their Personal Information, as described below, no more than twice in a 12-month period. Please note that when submitting a request, you may be asked to provide information to verify your identity before action is taken. California law permits California Consumers to use an authorized agent to make Consumer rights requests on their behalf. If you are an authorized agent of a California resident and are making a request on his or her behalf, you will be asked to provide a copy of the California resident’s written authorization (for example a power of attorney) showing that you have been granted the authority to submit a Consumer rights request on behalf of the California resident. To the extent that the written authorization provided to us is insufficient, we will contact you for further verification. We may additionally contact the California resident in order to verify his or her identity, and to confirm your authority to make a Consumer rights request on his or her behalf, prior to responding directly to you. We will respond to your request within the time period required by applicable law.
To make a Consumer rights request, California Consumers may submit a request online by clicking here. Consumers will be required to submit their name, contact email address, contact phone number, full permanent address, contract/order number (if known), a purchase amount and description of a recent purchase (if known) and/or a purchase date, and provide a brief description of their relationship to us so that we can verify the request.
A. THE RIGHT TO KNOW
If you are a California resident, you have the right to know about your Personal Information that we are currently maintaining and have Collected and disclosed. You also have the right to obtain a transportable copy of such Personal Information. Please note that we retain Personal Information for various time periods in accordance with applicable law and our internal recordkeeping policies and procedures.
California residents have the right to request more information regarding the following:

The categories of Personal Information we have collected about you
The categories of sources from which the Personal Information was collected
Our Business or Commercial Purposes for Collecting, Selling, or Sharing your Personal Information
The categories of Third Parties to which we disclosed your Personal Information
The categories of Personal Information we Sold or Shared about you and the categories of Third Parties to which each category of Personal Information was Sold or Shared
The categories of Personal Information that we disclosed for a Business Purpose, and for each category identified, the categories of Third Parties to which we disclosed that particular category of Personal Information
The specific pieces of Personal Information we have Collected about you

You may submit a request for this information as described above. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.
B. THE RIGHT TO DELETE
You may request that we delete your Personal Information that we have collected directly from you and are maintaining. Following receipt of a request to delete, we will let you know what Personal Information we can delete from our records, and we will direct any of our Service Providers that may have processed your Personal Information on our behalf to delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct Service Providers to delete your Personal Information from their records. For example, if we need to: (1) retain your Personal Information to complete a transaction or provide services to you; (2) detect security incidents; (3) protect against unlawful activities; (4) identify, debug, or repair errors; or (5) comply with a legal obligation. You may submit a request to delete as described above. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.
C. THE RIGHT TO CORRECT PERSONAL INFORMATION
You may request that we correct Personal Information that we maintain about you if you believe such Personal Information is inaccurate. We may request documentation from you in connection with your request. We will also require you (or your agent) to be verified before honoring your correction requests. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the Personal Information as you direct.
D. THE RIGHT TO LIMIT USE AND DISCLOSURE OF YOUR SENSITIVE PERSONAL INFORMATION
We will not use Sensitive Personal Information for the purpose of inferring characteristics about you, or for any other reasons besides the Business Purposes listed in Section 1. For this reason, we do not treat the Sensitive Personal Information we Collect as subject to a Limit the Use of My Sensitive Personal Information request and, therefore, we do not offer a way for you to submit such a request.
E. YOUR OPT OUT RIGHTS
You have the right to opt out of the Sale or Sharing of your Personal Information via cookies and tracking technologies on our Sites where we engage in such practices by clicking the “Do Not Sell or Share my Personal Information” link in the footer of our Site.
You may also opt out of the Selling or Sharing of your Personal Information through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.
On certain JLM System Sites we do not engage in Sales or Sharing and will not offer these opt out rights.
F. THE RIGHT TO NON-DISCRIMINATION
You have the right to not receive discriminatory treatment for exercising your CCPA privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
California Shine the Light
California law permits customers in California to request certain details about how their personal information is shared with third parties if personal information is shared for those third parties’ own direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at [email protected].
Any such request must include your name and “California Shine the Light Privacy Rights Request” in the first line of the description and, if sent by mail, must include your street address, city, state, and zip code.
Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through those provided under this section. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
How To Contact Us
For more information on your California privacy rights, or for privacy-related questions, contact us via email at: [email protected].