The Website (the “Website”) located at jones-dilworth.com is published and maintained by Jones-Dilworth, Inc., an Austin, TX corporation (“we,” “us,” “our,” or other similar pronouns).

This Privacy Policy explains, in general, what Personal Information (as defined below) is collected on the Website, how the information is used, and with whom we may share such information. By visiting the Website, and/or using any capability, software or service that may be made available through the Website, you agree to the terms of this Privacy Policy as they may be amended from time to time. As we update and expand our services, this Privacy Policy may change, so check back to this page from time to time. If the introduction of updated or expanded services results in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these updated or expanded services, they will be subject to this Privacy Policy.

This Privacy Policy is incorporated into, and part of, the Website Terms of Use posted by us with respect to any capability, software or service that may be made available through the Website, which also governs your use of the Website and such other capability, software or service in general. This Privacy Policy does not apply (i) to information that you may provide to us, or that we may obtain, other than through the Website or such capability, software or service, such as by phone, through postal mail and through other live and print media or (ii) to information that is not Personal Information.

1. PURPOSE

   Your privacy is important to us. In order to make your visits to the Website and use of any capability, software or service that may be made available through the Website as worthwhile as possible, we may ask you for Personal Information and we may collect certain information from your computer when you visit us. The aim of this notice regarding our Privacy Policy is to:
   • Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
   • Explain the way we use the personal data that you share with us in order to give you a great experience when you are using any of our capabilities, software or services that may be made available through the Website; and
   • Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy. We hope this helps you to understand our privacy commitments to you.

2. PERSONAL INFORMATION

   “Personal Information” is information that can be used to identify, locate, or contact an individual, including, for example, the individual’s name, postal address, e-mail address, telephone, wireless and/or fax number, demographic information, employment or education-related information, and/or other information that may identify the individual or allow online or offline contact with him/her. It also includes other information to the extent that it is associated with Personal Information.

3. WHAT PERSONAL INFORMATION IS COLLECTED ON THE WEB SITE?

   Personal Information is collected as part of the application and registration process on the Website. Personal Information includes, but is not limited to, family name, given name, address, email, and phone number. Additionally, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs (“Website Usage Information”).

4. USER-PROVIDED PERSONAL INFORMATION

   We also collect Personal Information from persons access or use any capability, software or service that may be made available through the Website, through such users’ activities, submission of information or materials or completion of online forms on the Website and/or registration for use of or access or use of any such capability, software or service, including, for example, when users submit information or materials on or through the Website or such other capability, software or service, send us an e-mail, or in any other way submit Personal Information to us via the Website.

5. HOW IS THE PERSONAL INFORMATION USED?

   We may use your Personal Information:
   • to operate, maintain or improve the Website, any capability, software or service that may be made available through the Website or our business;
   • to respond to your requests or inquiries;
   • to support auditing, legal or compliance functions;
   • to contact you, including to request your feedback on any of our capabilities, software or services;
   • to keep our capabilities, software and services safe and secure (for example, for fraud monitoring and prevention);
   • to manage your account; and/or
   • to maintain our internal record keeping.
6. We may also link this information with other information that you provide to us or that we obtain from other sources and Website Usage Information (as defined below). We may analyze user behavior as a measure of interest in, and use of, the Website and/or any capability, software or service that may be made available through the Website and e-mails, both on an individual basis and in the aggregate.

7. DO WE SHARE PERSONAL INFORMATION AND WEB SITE USAGE INFORMATION WITH OTHERS?

   We may process or share your data that we hold based on the following basis:
   • Consent: We may process your data if you have given us specific consent to use your Personal Information for a specific purpose.
   • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
   • Performance of a Contract: Where we have entered into a contract with you, we may process your Personal Information to fulfill the terms of our contract.
   • Legal Compelled Disclosure: We may disclose Personal Information to government authorities, and to other third parties when compelled to do so by government authorities or regulators, at our discretion, or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas, regulator requests or to enforce our legal rights or agreements with you or others. We also may disclose Personal Information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Website, or anyone else that could be harmed by such activities.
   • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
8. More specifically, we may need to process your data or share your personal information in the following situations:
   • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
   • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
   • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
   • We have not disclosed or sold any Personal Information to third parties for a business or commercial purpose in the preceding 12 months.

9. SERVICE PROVIDERS

   We may use third-party partners to help operate the Website and/or any capability, software or service that may be made available through the Website, and, as discussed above, may share your information with our affiliates and related entities, service providers and other third parties that provide products or services for or through the Website and/or any capability, software or service that may be made available through the Website or for our business (such as Web site or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf).

10. COOKIES AND RELATED TECHNOLOGIES AND WEB SITE USAGE INFORMATION

    When you use the Website and/or any capability, software or service that may be made available through the Website, we collect Website Usage Information. As you use the Website and/or any such capability, software or service, your browser and devices communicate with servers operated by us and services providers to coordinate and record the interactivity and fill your requests for services and information. The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to us by your computers or mobile devices. These servers are operated and the cookies managed by us, our business partners or our service providers. For example, when you access the Website and/or any such capability, software or service, we and our service providers may place cookies on your computers or mobile devices. Cookies allow us to recognize you when you return so you will not be required to register again for use of the same and track your use of the Website and/or any such capability, software or service. They also help us to detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your registration and your use of the Website and/or any such capability, software or service. Some cookies contain numbers that allow us to connect the Website and/or any such capability, software or service activity with other information we store about you in your profile or as related to your interactions with the Website and/or any such capability, software or service. Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided and storing such information.Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us or our service providers. These tools allow us to measure response to our communications and improve the Website and/or any such capability, software or service.We collect many different types of Website Usage Information. For example, we may collect information from the devices you use to access the Website and/or any capability, software or service that may be made available through the Website, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP”) addresses of the devices you use to interact with the Website and/or any such capability, software or service. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet.In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about users of the Website and/or any such capability, software or service to optimize same and understand its usage patterns. In other cases, we may associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy governs how we use that information.Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our capabilities, software or services.

11. AGGREGATE STATISTICS

    We may disclose aggregate statistics regarding user behavior as a measure of interest in, and use of, the Website and e-mails to third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user.

12. SECURITY

    While we will endeavor to protect the security and integrity of sensitive Personal Information provided to the Website and/or any capability, software or service that may be made available through the Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information will be absolutely safe from intrusion by others, such as hackers, during transmission through the Internet or while stored on our system or otherwise in our care. If you contact us by e-mail or a “contact us” or similar feature on the Website and/or any capability, software or service that may be made available through the Website, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification.

13. CONSENT TO WORLDWIDE TRANSFER AND PROCESSING OF PERSONAL DATA

    By providing Personal Information to us through the Website and/or when you register for use of or use any capability, software or service that may be made available through the Website, you understand that it may be used by us and our affiliates for the purposes described herein, and you further understand and consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, which may have different privacy laws from your country of residence and which may afford varying levels of protection for your Personal Information, and such laws may not be as comprehensive as those that exist in your country or residency. Regardless of the laws in place in these countries, we will treat the privacy of your information in accordance with this Privacy Policy. By providing your Personal Information to the Website, you consent to our transmission to, and processing of your information in, any jurisdiction, in accordance with this Privacy Policy.

14. PRIVACY POLICIES OF THIRD PARTY WEBSITES

    This Privacy Policy only addresses the use and disclosure of Personal Information we collect from you. Other websites that may be accessible through the Website have their own privacy policies and data collection, use and disclosure practices. If you link to any such website, we urge you to review its privacy policy. We are not responsible for the policies or practices of third parties.

15. LENGTH OF TIME PERSONAL INFORMATION IS RETAINED

    We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

16. CONTROLS FOR DO-NOT-TRACK FEATURES

    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

17. CALIFORNIA SPECIFIC PROVISIONS

    California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us.If you are under 18 years of age, reside in California, and have a registered account with us, you have the right to request removal of unwanted data that you publicly post on our services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed by us, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

18. CHILDREN

    Minors under the age of 18 may not use the Website. We do not collect or maintain information from anyone known to be under the age of 13, and no part of the Website is designed to attract anyone under the age of 13.

19. CHANGES TO THIS PRIVACY POLICY

    We reserve the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of the Website by posting such changed or updated Privacy Policy on this page. Any changes or updates will be effective immediately upon posting to the Website. Under certain circumstances, we may also elect to notify you of any changes or updates to our Privacy Policy by additional means, such as posting a notice on the front page of the Website to sending you an email.

20. INQUIRIES

    If you have any questions or comments regarding our privacy practices, you may contact us at hello@jones-dilworth.com

Effective since: October 31, 2023