Privacy Statement

Our Privacy Policy is part of our approach to transparency and protection of your Personal Information.

This Privacy Policy describes how JetStream collects, uses, and shares your Personal Information when you use our products, visit our websites and apps, and interact with us offline (collectively, the “Services”). It also tells you about the rights and choices you may have with respect to your personal information. For information on how to exercise your privacy rights, please see “Your Privacy Rights and Choices” section below.

JetStream may offer certain products, programs or Services that have unique or additional terms, privacy policies and/or consent forms that explain how JetStream processes Personal Information. For details on product-specific features, notices, or terms, please review the terms for the products and Services.

Please take a moment to familiarize yourself with our Online Terms and Conditions and this Privacy Policy, and contact us if you have any questions through the “How Can I Contact JetStream” section below.

Please be aware that if you are using a third-party device (for example, a voice-controlled intelligent personal assistant device or service) to access an JetStream website or application, the third-party device supplier may collect information, including Personal Information, via the device, even when JetStream does not, and you will need to contact that third-party device supplier directly to obtain any such information.

HOW DOES JETSTREAM DEFINE PERSONAL INFORMATION?

“Personal Information” is information that identifies or relates to you as an individual or could be used to reasonably identify you. Personal Information includes “personal data” as that term is defined in applicable U.S. State Privacy Laws. Personal Information also includes “Sensitive Personal Information” and “Sensitive Data” (collectively referred to as “Sensitive Personal Information” herein) as those terms are defined by applicable U.S. state privacy law. Personal Information does not include information that is publicly available, de-identified, or aggregated. Examples of Personal Information include, but are not limited to, your name, email address, mailing address, phone number, date of birth and gender. Examples of what may be considered “Sensitive Personal Information” may include Personal Information that reveals a consumer’s Social Security, driver’s license, state identification card, or passport number; account login, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer; Personal Information collected and analyzed concerning a consumer’s mental or physical health condition or diagnosis, medical history or treatment, sex life, or sexual orientation; citizenship or citizenship status; and Personal Information collected from a known child, as defined in applicable U.S. State Privacy Law. Additionally, under applicable U.S. Sate Privacy Laws, inferences drawn from Personal Information which are used to indicate an individual’s racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship status may also be considered Sensitive Personal Information.

HOW DOES JETSTREAM COLLECT PERSONAL INFORMATION?

JetStream collects Personal Information online and offline in a few different ways:

• Personal Information that you provide. We may collect Personal Information and other information that you provide when you use our Services, participate in a promotion program, attend JetStream programs or events, engage with customer service on phone calls and any other data that you may choose to submit or provide. With your permission, we may also collect data from another source like a device or social media account. Such information may include, but not be limited to, contact information (such as your name, postal address, email address, telephone number, user ID and password), date of birth, professional credentials, experiences, activities, skills, preferences, hobbies and interests.

• Personal Information from public or third-party sources. We may collect data from public sources including, but not limited to, social media and other websites that enable social sharing. We may also collect Personal Information from government agencies, public or third-party information sources, third-party service providers, or business partners. In addition, we also may collect information from industry and associations or combine information we have collected from multiple sources. We may engage third-party service providers to provide certain interactive features on our Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on our Services to assist you with your order and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.

• Personal Information collected from devices you use to connect with us or use our Services. JetStream collects data through our websites and apps and automatically from devices you use to connect to our Services.

• Personal Information collected when you make a purchase. When you make a purchase on our website, we will collect Personal Information to process, fulfill, and ship your order.

• Personal Information collected with business partners. We sometimes work with other organizations to provide you with our Services. When that happens, we require that information be protected.

If you choose to submit any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

From time to time, we may use or augment the Personal Information we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. We may also combine information we get from a third party with information we already have, and we may combine information that we have collected offline with information we collect online. To protect your privacy, you should not provide JetStream with any information that is not specifically requested.

You may also give us permission to access certain personal information maintained by other service providers. For example, you may link your social media or Google™ account to JetStream, which allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check those policies before granting JetStream access. You agree that we are not responsible for any acts or omissions by these social media service providers.

WHAT PERSONAL INFORMATION DOES JETSTREAM COLLECT AND WHY DO WE COLLECT IT?

JetStream may collect, use, and disclose the following types of Personal Information:

We may use any of the categories of Personal Information listed above for our internal business purposes, such as data analysis, audits, developing new products, enhancing our Services, identifying usage trends and determining the effectiveness of our promotional campaigns. We may also use inferences drawn from Personal Information to create a profile reflecting your preferences.

At your direction, we may disclose your Personal Information to partners or other organizations with which we jointly develop and/or promote our Services.

We may de-identify and/or aggregate data we collect about customers and site visitors and use it for any purpose, including analytics, product and service development and improvement activities. We take reasonable measures, including, but not limited to, processing the data in its de-identified form as required or permitted by law, including where we may attempt to reidentify the data. We may also combine information we gather about you on our JetStream websites and Services with our offline records, as well as records provided by third parties. We use this consolidated information to help us better design JetStream websites, products, and services to communicate information to you, to enhance our marketing and research activities, to serve you more relevant advertising and for other purposes, as disclosed to you from time to time.

Where required by applicable law, JetStream will collect your Sensitive Personal Information with your consent. Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any Sensitive Personal Information on or through the website, in webforms or otherwise to us.

WHAT PERSONAL INFORMATION DOES JETSTREAM SELL, DISCLOSE, OR USE FOR TARGETED ADVERTISING?

JetStream does not sell your Personal Information for money, but some of the ways in which we may disclose your Personal Information to certain third parties that provide services to us, such as analytics and targeted advertising services, may be considered a “sale” under certain applicable U.S. State Privacy Laws. We do not have actual knowledge that we sell or share the Personal Information of consumers under 18 years of age. We may “sell” or disclose to third parties for cross-context behavioral advertising, targeted advertising or other marketing purposes the following categories of Personal Information:

• Identifiers

• Internet or other electronic network activity information

• Geolocation data

The third parties to which this Personal Information is “sold” or disclosed are advertisers and analytics vendors, which upon receipt of Personal Information may process it according to their own practices as described in their privacy policies.

We may allow certain companies to place tracking technologies, such as cookies or tracking pixels on our websites. Those companies receive information about your interaction with our websites that is associated with your browser or device and may use that data for targeted advertising (i.e., to serve you relevant ads on our websites or others). For more information, please see JetStream’s Cookie Policy.

At JetStream’s discretion, it may also disclose aggregated, anonymized, or de-identified information that is not personally identifiable to third parties.

RETENTION

We will keep your Personal Information in our records for as long as necessary for the purposes described in this Privacy Policy or otherwise authorized by law. This includes providing you with a service you have requested from us or to comply with applicable legal requirements. It also includes keeping your Personal Information for so long as there is any possibility that you or we may wish to bring a legal claim, or where we are required to keep your personal information for legal or regulatory reasons. We may also retain your personal information where such retention is necessary in order to protect your vital interests or the vital interests of another natural person. Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. If you wish to receive further information regarding our record retention procedures, please contact us using the contact details provided under the “How Can I Contact JetStream?” section below.

YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you reside, you may have certain rights and choices (with certain limitations and exceptions) regarding our processing of your Personal Information. Please note that some of these rights may vary depending on your state of residence and whether your state has an applicable U.S. State Privacy Law.

Residents of states with applicable U.S. State Privacy Laws may have certain rights with respect to the collection and use of their Personal Information. Those rights may vary by state. Such rights may be effectuated by submitting a request by clicking Privacy Rights Request. The potential rights include the right to:

• Know the categories and/or specific pieces of Personal Information collected about you, including the categories from which the Personal Information is collected, the business purpose for collecting the Personal Information, whether your Personal Information was disclosed to third parties, the categories of Personal Information, if any, that we disclosed to third parties, the categories of and/or the third parties to whom your Personal Information was disclosed

• Access or obtain a copy of the specific pieces of Personal Information we retain about you

• Request deletion of your Personal Information

• Request correction of inaccurate Personal Information

Once you have submitted your request, we will respond within the time frame permitted by the applicable U.S. State Privacy Law. To help protect the security of your Personal Information, JetStream will need to verify your identity in connection with any requests. We may contact you by email to verify your request. Depending on your request, we may ask you for information such as your name, an email address, or phone number that you have used with JetStream. We take steps to ensure that only you or your authorized representative can exercise rights with respect to your Personal Information.

You may be permitted to make certain requests through an authorized agent. For all requests via authorized agents, we require that your agent provide us with your Personal Information as required on the request form and provide signed documentation demonstrating that you authorized the agent to submit a request on your behalf. If you are an authorized agent making a request, we may require and request additional information to protect the Personal Information entrusted to JetStream.

There may be situations where we cannot grant your request, for example, if you make a request for access and we cannot verify your identity, we will not be able to comply with the request. We may also be unable to comply with your request to delete if we have a legal or regulatory obligation to keep your Personal Information, such as when you participate in scientific research. Other reasons your request may be denied are if it jeopardizes the privacy of others or would be impracticable to honor.

Where we deny your request in whole or in part, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial. Residents of certain states may have the right to appeal JetStream’s decision to deny your request regarding your Personal Information, in whole or in part. To appeal our decision, please contact us. We will process and respond to your appeal within the time frame permitted by the applicable U.S. State Privacy Law.

We will not discriminate against you if you exercise your rights as described in this Privacy Policy. For example, we will not deny goods or Services to you, or charge you different prices or rates, or provide a different level of quality of products or Services. We will not restrict or deny you access to our Services or provide a different level of quality of products or Services because of choices and requests you make in connection with your Personal Information. Please note, certain choices may affect our ability to deliver JetStream products and services. For example, if you sign up to receive marketing communications or promotions, then ask JetStream to delete all of your Personal Information, we will be unable to send you marketing communications or promotions.

Additionally, requesting to delete your personal information will include deletion of any accounts you may have created with us as well as any memberships in any of our financial incentive programs and you may no longer receive the rewards and promotions related to those programs.

You may exercise any of your applicable rights and choices set forth above in relation to your Personal Information by contacting us using the details provided under the “How Can I Contact JetStream” section below.

GLOBAL PRIVACY CONTROL (GPC) SIGNAL

JetStream recognizes the Global Privacy Control (“GPC”) where required by applicable U.S. State Privacy Law. Residents of states requiring GPC recognition may opt-out of the “sale” or disclosure of Personal Information for cross-context behavioral advertising purposes and/or targeted advertising as those terms are defined by applicable U.S. State Privacy Laws. To communicate your desire to opt-out, you may configure your browser to turn on the GPC signal, which will transmit your opt-out request to JetStream automatically.

To turn on the GPC signal, you can download one of the supported browsers or extensions. You may visit https://globalprivacycontrol.org/#download for a list of the available browsers or extensions. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

MARKETING

If you no longer wish to receive promotional marketing materials from us, you may opt-out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from JetStream by following the instructions included in the email. We will work to comply with your request as soon as we can. Please be aware that once you have opted out of these programs, you will no longer receive any associated discounts, coupons or promotional offers that are part of the program.

However, even if you opt out of receiving such communications, we may need to continue to send you certain non-marketing communications (such as information about changes to our Privacy Policy or Terms of Use).

THIRD PARTY MARKETING

California law permits customers in California to request certain details about how their Personal Information is shared with third parties, and in some cases affiliates, if Personal Information is shared for those third parties’ or affiliates’ own direct marketing purposes. We do not share Personal Information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at privacy@JetStream.security Alternatively, you may send a letter to the following address:

JetStream Security Inc.

Attn: Privacy Team / Data Protection Officer
5201 Great America Parkway, Suite 346
Santa Clara, CA 95054

Email: support@jetstream.security

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.

HOW DOES JETSTREAM KEEP PERSONAL INFORMATION SECURE?

It is JetStream’s practice to take steps to secure our JetStream Services. However, the confidentiality of information transmitted over the internet cannot be guaranteed. We urge you to exercise caution when transmitting Personal Information over the internet, especially Personal Information related to your health. JetStream cannot guarantee that unauthorized third parties will not gain access to your Personal Information; therefore, when submitting Personal Information to JetStream websites or apps, you must weigh both the benefits and the risks. JetStream websites or apps may link to third-party websites that are not controlled by JetStream or subject to an JetStream privacy policy. You should check the privacy policies of such third-party websites before submitting Personal Information.

CHILDREN’S INFORMATION

JetStream does not knowingly collect or use any Personal Information from children (we define “children” as minors younger than 13). We do not knowingly allow children to order our products, communicate with us, or use any of our online Services. If you are a parent or guardian and become aware that your child has provided us with Personal Information, please contact us using one of the methods specified under the “How Can I Contact JetStream” section below and we will work with you to address this issue.

THIRD-PARTY SITES

We may provide links to websites and other third-party content that are not owned or operated by JetStream. The websites and third-party content to which we link may have separate privacy notices or policies. JetStream is not responsible for the privacy practices of any entity that it does not own or control.

If you provide any Personal Information through a third-party site, your interaction and your Personal Information will be collected by, and controlled by the privacy policy of, that third-party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

COOKIES AND OTHER TECHNOLOGIES

JetStream’s online Services, interactive applications, and advertisements may use cookies and other technologies such as web beacons. We use this information to better understand, customize and improve user experience with our websites, Services and offerings as well as to manage our advertising. This information can make your use of our JetStream Services easier and more meaningful by allowing JetStream and our service providers to provide better service, customize sites based on consumer preferences, compile statistics, provide you with more relevant advertisements based on your interests, analyze trends and otherwise administer and improve our products and Services. If we have collected your Personal Information, we may associate this Personal Information with information gathered through the Tools.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.

You can also control Flash cookies which we may use on certain JetStream websites and apps from time to time by clicking here. Why? Because Flash cookies cannot be controlled through your browser settings. Choices you make are both browser and device specific.

Here are some of the types of information collected when visiting JetStream Websites:

• Log data: When you use JetStream websites and apps, our servers automatically record information (“log data”), including information that your browser sends whenever you visit a website or app or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the webpages you visited that had JetStream features, browser type and settings, the date and time of your request, how you used websites and cookie data.

• Cookie data: Depending on how you are accessing JetStream’s online Services, we and our service providers may use “cookies” (a small text file sent by your computer each time you visit our sites, unique to your JetStream account or your browser) or similar technologies to record log data. For more information, see our Cookie Policy. We may use Google Analytics™, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt-out of them by downloading the Google Analytics™ opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

• Social media plug-ins and data. Social media plug-ins (e.g., the Facebook® “Like” button, “Share to Twitter” button) enable you to easily share information with others. The operator of the social plug-in can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. If you are logged into the social media website (e.g., Facebook®, Twitter™, Google+) while browsing on our websites, the social plug-ins allow that social media website to receive information that you have visited our websites. The social plug-ins also allow the social media website to share information about your activities on JetStream with other users of their social media website. JetStream does not control any of the content from the social plug-ins. For more information about social plug-ins from other social media websites, you should refer to those sites’ privacy and data-sharing statements.

• Linked accounts. If you choose to link your social media or Google™ account to JetStream, this allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check these policies before granting us access.

• Device information. We may also collect information about the device you are using to access our JetStream Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. To learn more about what information your device may make available to us, please check the policies of your device manufacturer or software provider.

INTEREST-BASED ADVERTISING

JetStream hopes to deliver to you advertising for products and Services you need or want. JetStream, its service providers and partners use common tracking tools, such as cookies, pixels, web beacons, and similar technologies, to automatically collect Personal Information about users for purposes of enhancing their online experience and delivering more meaningful advertisements. Like many companies, JetStream may also utilize third-party advertising vendors and other partners to collect this information. Certain laws define this as “cross-context behavioral advertising.”

Like many companies, we place advertisements where we think they will be most relevant to customers. One way we do so is by allowing network advertising companies with whom we work to place their own Tools when an individual visits JetStream websites and apps. This enables the network advertising company to recognize individuals who have previously visited JetStream websites and apps and to serve you ads based on your web browsing activity, purchases, interests and/or other information — a practice commonly referred to as interest-based advertising (IBA) or online behavioral advertising (OBA).

These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use.

Retargeting. One way in which we deliver more meaningful advertisements is through a common form of online advertising known as “retargeting” or “remarketing.” Retargeting works by serving ads on one site based on an individual’s online activities on a different, unrelated site. For example, if you look at an JetStream product on an JetStream website, you may later see an advertisement for that JetStream product when you visit third-party sites. To do this, JetStream or its advertising service providers may use a device ID, cookie, pixel, web beacon or similar technology placed by JetStream or our service provider when you visit JetStream websites or apps or third-party websites or apps. The placing of these cookies or other technologies on your device may enable you to be identified across multiple websites. You should consult the privacy policies of our service providers and other websites that you visit to understand how they collect and use your data.

TRANSFER OF PERSONAL INFORMATION BETWEEN COUNTRIES

Any Personal Information you provide to JetStream may be stored and processed, transferred between and accessed from the United States, where JetStream is headquartered, and other countries which may not guarantee the same level of protection of Personal Information as the one in which you reside. However, JetStream will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored/accessed.

HOW CAN I CONTACT JETSTREAM?

To exercise any rights you might be entitled to under applicable U.S. State Privacy Laws, please utilize the designated mechanisms provided in the “Your Privacy Rights and Choices” section, above.

If you have other questions about your Personal Information, please contact us by clicking on the “Contact Us” link on the website you are visiting or by emailing us at privacy@JetStream.security. Alternatively, you may send a letter to the following address:

JetStream Security Inc.

Attn: Privacy Team / Data Protection Officer
5201 Great America Parkway, Suite 346
Santa Clara, CA 95054

Email: support@jetstream.security

In all communications to JetStream, please include the email address used for registration (if applicable), the website address or the specific JetStream program to which you provided Personal Information and a detailed explanation of your request. We will do our best to respond to all reasonable requests in a timely manner.

HOW WILL I KNOW WHETHER JETSTREAM HAS UPDATED THIS PRIVACY POLICY? JetStream reserves the right to amend this Privacy Policy at any time. If JetStream changes its privacy practices, a new Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth at the top of this Policy.