DISCIPLINES KEY MARKETS ABOUT US OUR VALUES CONTACT US CAREERS Privacy Policy Privacy Policy Last updated: August 17, 2020 PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE. THIS SITE IS INTENDED FOR USERS LOCATED IN THE UNITED STATES, AND IT IS NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA. BY USING THIS SITE, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE USING THE SITE FROM WITHIN THE UNITED STATES. Introduction Phillips & Jordan, Inc. (also referred to herein as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat your personal information. You may obtain an accessible version of this Policy by contacting us via the “Contact Us” details at the end of this Policy. This Privacy Policy (the “Policy”) provides you with a description of our online and offline practices regarding your personal information and the rights you have regarding your personal information. We collect and process personal information online via our website, www.pandj.com/ (the “Site”). What Information Do We Collect? We collect the following information from you for the purposes described in the “How Do We Use and Share Your Information?” section of this Policy. Category Description Contact Information When you visit the Site, request information about our services, or contact us for additional information, we may ask you for your name, address, telephone number, email address, or other contact details needed to respond to your request or inquiry. Your Communications and Feedback When you communicate with us or provide feedback, including by email or phone and using the Contact page of the Site, we may retain your communications in order to process and respond to them, as well as to improve our services. We may use your email address and phone number to communicate with you about our services. We may request that you provide additional information relevant to any support requested. Usage Information When you visit the Site, we automatically collect information from your browser or your mobile device, which includes the date and time of your visit, your location, your Internet Protocol (IP) address or unique device identifier, your domain server, your operating system, your browser type, your access time, and data about which pages you visit. Cookies and Similar Technologies When you visit the Site, we collect cookies and use similar technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly. Subcontractor Data When you complete a Subcontractor Registration form on our Site, we collect your name and email, as well as your company’s name, contact person, address, phone number, and other business information that allows us to assess your candidacy for work on a contract. We also collect information on your business’s civil, criminal, and regulatory history. We may supplement the information with additional information about you and your company obtained from publicly available and third-party databases or services that provide information about business people and companies (including an individual’s name, job title, business contact information, and company information). CCPA Notice at Collection. For purposes of the California Consumer Privacy Act (CCPA), in collecting the information described above, we collect the categories of personal information listed below. Please also see the “California Rights” section of this Policy for additional information. If your information is collected in the context of a business relationship with us, it may not be covered by the CCPA. CCPA Category Description Identifiers When collecting Contact Information, we will receive your name, address, telephone number, email address, and other contact details. When collecting Your Communications and Feedback, we will receive your name, email address, a message number, a tracking URL number, and other information that you may provide. When collecting Cookies and Similar Technologies and Usage Information, we will receive your Internet Protocol (IP) address or unique device identifier. When collecting Subcontractor Data, we will receive your name, address, telephone number, email address, information about your business and professional experience, and any additional information you choose to provide. Categories of personal information described in the California Customer Records statute When collecting Contact Information, we will receive your name, address, telephone number, and other contact details. When collecting Your Communications and Feedback, we will receive your name and other information that you may provide. When collecting Subcontractor Data, we will receive your name, address, telephone number, email address, information about your business and professional experience, and any additional information you choose to provide. Characteristics of protected classifications When collecting Subcontractor Data, we will receive information you choose to provide on the ownership of your business related to contract eligibility, which could include characteristics of protected classifications. Internet or other electronic network activity information We collect Cookies and Similar Technologies as described in the “Cookies and Similar Technologies” section of this Policy. When collecting Usage Information, we will automatically receive information from your browser and your device, which includes the date and time of your visit as well as your location, domain server, operating system, browser type, access time, and data about which pages you visit. Geolocation data When collecting Contact Information, we will receive your address. When collecting Cookies and Similar Technologies and Usage Information we will receive your location while using the Site. When collecting Subcontractor Data, we will receive your location and time zone. Audio, electronic, visual, thermal, olfactory, or similar information When collecting Your Communications and Feedback, we will receive and retain your communications. Professional or employment-related information When collecting Subcontractor Data, we will receive your name and email, as well as your company’s name, contact person, address, phone number, other information about your business and professional experience, and any additional information you choose to provide. We also collect information on your business’s civil, criminal, and regulatory history. No Sensitive Personal Information. Our intent is to not collect any sensitive personal information from you. Sensitive personal information includes but is not limited to: race or ethnic origin, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, or sexual life. We request that you do not provide us with sensitive personal information of this nature. Is entry of personal information required? You may choose not to provide any personal information, and you may still access and use much of the Site. However, you will not be able to access any portions of the Site that require your personal information. Some pages on the Site may give you the option of providing certain of your personal information about yourself. Cookies and Similar Technologies First-Party and Third-Party Cookies A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Permanent” or “persistent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the site you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than the website you are visiting. Similar Technologies In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website: Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels”) with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are rendered invisible on web pages when you open a page. Social Widgets: These are buttons or icons provided by third-party social media providers that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties. UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the http or https address entered to go to a web page) when you move from one web page or website to another, where the string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website. What Cookies and Similar Technologies Are in Use and Why Do We Use Them? We use first-party and third-party cookies and similar technologies as described below: Facebook Connect. We use Facebook’s technologies to serve relevant advertisements and to track Facebook ad-driven visitor activity on the Site. Facebook Connect also gives you the option to post information about your activities to your profile page to share with others within your network by using a single sign-in service to authenticate your identity. You may learn more about Facebook’s policies by visiting https://www.facebook.com/policy.php, and you can also find instructions for opting out of receiving advertisements via that page. Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Site. The information stored in the cookie is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en). Google Analytics relies on the following cookies: Cookie Description Type Duration _ga Used to distinguish users. Analytics 2 years _gat Used to throttle request rate. Analytics 1 minute _gid Used to distinguish users. Analytics 1 day Google Marketing (DoubleClick). We use Google’s marketing technologies to track user activity on the Site and to serve personalized advertisements. Your browser is assigned a pseudonymous ID used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, you can visit https://policies.google.com/technologies/ads, https://support.google.com/displayvideo/answer/7621162, and https://support.google.com/google-ads/answer/7548399?hl=en. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy. Google’s technologies use the following cookies: Cookie Description Category Duration IDE This cookie is used by Google DoubleClick and stores information about how end users use the Site and any other advertisement before visiting the Site. This is used to present users with ads that are relevant to them according to the user profile. Marketing 2 Years Other Cookies. We also use other first-party cookies to provide certain aspects of the Site: Cookie Description Category Duration cookielawinfo-checkbox-necessary This cookie is set by our GDPR Cookie Consent plugin. The purpose of this cookie is to check whether or not the user has given the consent to the usage of cookies under the category 'Necessary'. Functional 1 Hour viewed_cookie_policy The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data. Functional 1 Year Other Third-Party Technologies Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies. Choices About Cookies We provide you with choices regarding the information you provide to us, and we have created ways to give you control over your information. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Site. Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Site. In addition, adjusting the cookie settings on the Site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the Site. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browser providers: Google Chrome: https://support.google.com/chrome/answer/95647?hl=en Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265 To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/. How Do We Use and Share Your Information? How do we use the information described in this Policy? To the extent permitted by applicable law, we may use the types of personal information listed above in order to: Operate and improve our business and the Site; Provide you with the services, content, and functionality you request; Honor our terms of use and contracts; Manage our relationships with you; Process payments or other transactions; Improve our services and develop new services; Maintain our databases and back-ups, including records of our communications with you; Ensure the privacy and security of our Site and services; Detect fraud and prevent loss; Improve our customer service; Communicate with you and respond to your feedback, requests, questions, or inquiries; Promote our products and services to you; Contact you about other products and services; Improve our marketing efforts, including by providing more tailored advertising; Administer a contest, promotion, or survey; Assess the success of our marketing and advertising campaigns; Support and improve the Site, including evaluations of functionality and features; Analyze use of the Site and our services and prepare aggregate traffic information; Recognize your device and remember your preferences and interactions; Provide you with a more personal and interactive experience on the Site; Determine and track user interests, trends, needs, and preferences; Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transfers; Obtain and maintain insurance coverage, manage risks, and obtain professional advice Accomplish any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your information was provided to us; Accomplish another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law; Comply with federal, state, or local laws; Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, order, or summons by federal, state, or local authorities; Cooperate with law enforcement agencies; Exercise or defend legal rights or claims; and Collect, create, use, retain, sell, or disclose deidentified or aggregated data. How do we disclose or share the information described in this Policy? Where permitted by applicable law, we may share the information described above in the following contexts: Category Description Corporate Affiliates We may share your information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents. Acquisitions and Similar Transactions We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Disclosures with Your Consent We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent. Legal Obligations and Rights (Subpoenas, Court Orders, and Warrants) We may disclose your information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our legal rights; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts. Third Parties We may provide information about you to third parties that may offer products and services specifically requested by you. If you complete a Subcontractor Registration, we may disclose personal information about you and your business to third parties, including government authorities, for purposes of assessing our eligibility for a contract. Service Providers We may share your information with our service providers that need access to your information to provide operational or other support services on our behalf. Among other things, service providers help us to administer the Site; support our provision of services requested by you; provide technical support; send communications to you; and assist with other legitimate purposes permitted by law. Professional Advisors We may share your information with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf. Deidentified or Aggregated Data We may disclose aggregated information about our users and information that does not identify any specific individual, such as groupings of demographic data and customer preferences. How Long Do We Store and Use Your Information? We will retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements. We take reasonable steps to delete the information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our legal obligations or business objectives. To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement. We are required by law to maintain records of consumer requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes. If you are a resident of California, please see the California Residents section for more information. How Do We Protect Your Information? We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods. While our security measures seek to protect your personal information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information you transmit to or from our Site. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances. We use reasonable security measures when transmitting personal information to consumers in response to requests under the California Consumer Privacy Act. We have implemented reasonable security measures to detect fraudulent identify-verification activity and to prevent the authorized access to or deletion of personal information. If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law. Your Rights and Choices Regarding Personal Information Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or if you no longer want to receive any email, postal mail, or telephone contact from us in the future, such requests may be submitted via the “Contact Us” details at the end of this Policy. We honor such requests when we are required to do so under applicable law. Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at privacy@pandj.com and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action. Cookies. You may set your browser to refuse all or some browser cookies or to alert you when cookies are being set. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/. Online Tracking Signals. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals. Accuracy and Updating Your Information. Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us. Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy. California Residents Data Practices During the Last 12 Months Personal Information Collected: As described in this Policy, we have collected the categories of personal information listed below during the preceding 12 months: Identifiers Categories of personal information described in the California Customer Records statute Characteristics of protected classifications Internet or other electronic network activity information Geolocation data Audio, electronic, visual, thermal, olfactory, or similar information Professional or employment-related information Categories of Sources: We have collected the personal information identified in this Policy from you, public records, and our background check vendors. Business and Commercial Purposes for Collecting: We have collected the categories of personal information listed above for the following purposes: Operate and improve our business and the Site; Provide you with the services, content, and functionality you request; Honor our Terms of Use and contracts; Manage our relationships with you; Process payments or other transactions; Improve our services and develop new services; Maintain our databases and back-ups, including records of our communications with you; Ensure the privacy and security of our Site and services; Detect fraud and prevent loss; Improve our customer service; Communicate with you and respond to your feedback, requests, questions, or inquiries; Promote our products and services to you; Contact you about other products and services; Improve our marketing efforts, including by providing more tailored advertising; Administer a contest, promotion, or survey; Assess the success of our marketing and advertising campaigns; Support and improve the Site, including evaluations of functionality and features; Analyze use of the Site and our services and prepare aggregate traffic information; Recognize your device and remember your preferences and interactions; Provide you with a more personal and interactive experience on the Site; Determine and track user interests, trends, needs, and preferences; Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transfers; Obtain and maintain insurance coverage, manage risks, and obtain professional advice Accomplish any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your information was provided to us; Accomplish another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law; Comply with federal, state, or local laws; Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, order, or summons by federal, state, or local authorities; Cooperate with law enforcement agencies; Exercise or defend legal rights or claims; and Collect, create, use, retain, sell, or disclose deidentified or aggregated data. No Personal Information Sold. We have not sold categories of personal information during the preceding 12 months. Personal Information Disclosed for a Business Purpose. We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months: Identifiers Categories of personal information described in the California Customer Records statute Characteristics of protected classifications Internet or other electronic network activity information Geolocation data Audio, electronic, visual, thermal, olfactory, or similar information Professional or employment-related information We have shared these categories of personal information with the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) service providers (data analytics data storage, mailing, marketing, payment processing, Site administration, technical support); (4) government entities whom we may serve with Subcontractors; (5) operating systems and platforms, and (6) internet service providers. No Financial Incentive We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information. Do Not Sell My Personal Information Under the CCPA, you have the right to direct us to stop selling your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell personal information as defined under applicable law. CCPA Requests to Know and Requests to Delete The CCPA gives consumers the right to request that we (1) disclose what personal information we collect, use, disclose, and sell, and (2) delete certain personal information that we have collected or maintain. You may submit these requests to us as described below, and we honor these rights where they apply. However, by way of example, these rights do not apply where we collect or sell a consumer’s personal information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s personal information occurred in California, and (3) no personal information collected while the consumer was in California is sold. In addition, de-identified information is not subject to these rights. If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (1) treat the request as if it had been submitted in accordance with the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable. Request to Know You have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold and the categories of third parties to whom the personal information was sold; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling personal information; and (7) the categories of third parties with whom we share personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request. Submission Instructions. You may submit a request to know via 800.955.0876 or privacy@pandj.com. If you maintain an account with us, we may require you to submit the request through that account. Verification Process. We are required by law to verify the identities of those who submit requests to know, and our verification process is described in detail below. We will inform you if we cannot verify your identity. If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy. If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer. If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor. Request to Delete You have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described below, we will delete your personal information from our records and direct any service providers (as defined under applicable law) to delete your personal information from their records. Submission Instructions: You may submit a request to delete via 800.955.0876 privacy@pandj.com. We may present you with the choice to delete select portions of your personal information, but a global option to delete all personal information will be offered and more prominently presented. Verification Process. We are required by law to verify the identities of those who submit requests to delete, and our verification process is described in detail below. We will inform you if we cannot verify your identity. If we cannot verify the identity of the person making a request to delete, we may deny the request. If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor. Verification Procedures To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, address, telephone number, company, and/or email address. Authorized Agents Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with signed permission to do so; (2) verify your identity directly with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code. CCPA Non-Discrimination You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers for exercising their rights under the CCPA. California Shine the Light Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at privacy@pandj.com. Nevada Residents You may submit a verified request to us at privacy@pandj.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request. We will respond to your request in accordance with Nevada law. Third-Party Sites This Policy is applicable only to the Site, and it does not apply to any third-party websites. The Site may contain links to, and media or other content from, third parties. These links are to external resources and third parties that have their own privacy policies. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to external, third-party resources. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site. We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on this Site. Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website. Children’s Online Privacy Protection Act The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 13 or younger, nor is information knowingly collected from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or provide any information to or on the Site. If you are under 13, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 13, please contact us using the contact information provided below. For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule. Updates and Changes to This Policy We may add to, change, update, or modify this Policy to reflect any changes to how we treat your information or in response to changes in law. Should this Policy change, we will post all changes to this Policy on this page. Any such changes, updates, or modifications will be effective immediately upon posting on the Site. The date on which this Policy was last modified is identified at the beginning of this Policy. You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of the Site. Contact Us For more information, or if you have any questions or concerns regarding this Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone. In Writing: Phillips & Jordan, PO Box 52050, Knoxville, TN 37950 By Telephone: 865.688.8342 By Email: privacy@pandj.com My P&J10142 Parkside Drive, Suite 500 Knoxville, TN 37922 800.955.0876 865.688.0876 Privacy & Cookies Policy