Date Last Revised: Nov 21, 2018

BluJay Solutions Inc. and its affiliates (“BluJay Solutions”, “we”, “us”) are a global organization offering supply chain software and services to retailers, distributors, freight forwarders, manufacturers, and logistics service providers so they can manage and optimize their trade logistics.  We are committed to respecting the privacy of personal information that is shared with us, directly or indirectly, in connection with our customers’ use of our products and services. BluJay Solutions Co. is another U.S. entity that adheres to the Privacy Shield Principles.

BluJay Solutions complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. BluJay Solutions has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

This Privacy Policy (“Privacy Policy”) describes how we may collect, store, use, analyze and disclose information in connection with any products or services offered by BluJay Solutions, including through our website located at BluJaySolutions.com and any platforms or mobile applications we may offer, including our Global Trade Network ecosystem (collectively, the “BluJay Services” or “Services”). Due to the nature of our business, we often do not have a direct relationship with the individual whose information we may process in connection with our Services. Therefore, we rely on our customers to obtain any required consents for such processing, or to have another legally sufficient legitimate basis for processing, if applicable.

When you interact with or use the BluJay Services, you consent to such collection, use and sharing of information as described in this Privacy Policy, our Cookie Policy and our Terms of Use. If you do not consent to the terms of this Privacy Policy, do not continue to interact with or use the BluJay Services. 

European Residents:  Please see our European Privacy Policy for residents of the European Union, the European Economic Area or Switzerland.

Due to the global nature of our Services, our privacy practices may vary among the states, countries and regions in which we operate in order to comply with applicable legal requirements.

PRIVACY SHIELD NOTICE
We are in the process of submitting our certification of compliance with the EU-U.S. and Swiss-U.S. Privacy Shield with respect to the personal data of residents of the EU, EEA or Switzerland that is processed through the BluJay Services. We certify that we adhere to the Privacy Shield Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement (hereinafter, “Privacy Shield Principles”) for individuals in participating European countries whose personal data is processed through the BluJay Services. Once complete, our Privacy Shield certification will be available here. We may also process personal data relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses.

INFORMATION WE MAY COLLECT
Our Services gather certain information automatically, some of which may be considered personal information under applicable law.

We and users of our Services, including without limitation, our customers and partners such as retailers, distributors, freight forwarders, manufacturers, and logistics service providers, may collect, among other things, the following types of information:

  • Name
  • Address (including billing and shipping addresses)
  • Telephone number
  • Email address
  • Fax number
  • Professional information, such as employer or organizational affiliation for a customer or partner, or company or organizational entity name for a delivery pickup, transfer or destination location
  • Payment or financial information in order to process a purchase or transaction or for shipping fees
  • Unique IDs such as a cookie placed on a computer or mobile device, or device IDs
  • IP address or MAC address, and information derived from an IP or MAC address, such as geographic location
  • Browsing activities, cookies and similar data, and platform or mobile application use data
  • Referring domain, destination domain and destination path
  • Geo-locational data, including latitudinal and longitudinal data
  • Routing, pickup, transfer and delivery time and route information
  • User IDs and passwords for customers or partners with accounts on our Services
  • Information required by customs or other governmental authorities
  • Communication preferences
  • Other similar information

We, and users of our Services, may also collect information, including personal information, in the following situations:

  • Registration for the BluJay Services: Information such as name, email address, telephone number, company/organization, title, and other information, may be collected in connection with registration for or use of the BluJay Services (for example, to sign-up for and log into the BluJay Services). Customers may update their information by logging to their account.
  • Use of BluJay Services. Customers and others using our Services, such as retailers, distributors, freight forwarders, manufacturers, and logistics service providers, may collect information they need for their supply chain and trade logistics. Certain customers, such as insurance brokers or agents, may also collect certain information that may be regarded as sensitive in certain jurisdictions. We rely on such customers to obtain any required consents, or to have another legally sufficient legitimate basis for such collection if applicable.
  • Communications. Personal information may be collected, such as name, email address, and other information, when provided in any communications, whether via email, social media, phone or otherwise, including for support-related questions.
  • Surveys and Research. We may collect personal information from anyone participating in research and surveys.


USE OF INFORMATION
BluJay Solutions may use the information, including personal information, collected in connection with the BluJay Services for the purpose of providing the Services to our customers, as well as for supporting our business functions, such as fraud prevention, marketing, analytics and legal functions and other legitimate purposes.  Our customers may use such information in connection with their use of our Services.

To the extent permitted by applicable law and, for customer data, as permitted by our customer agreements, we may use information collected in connection with our Services:

  • To operate the BluJay Services and provide support.
  • To fulfill customer requests, such as to create a BluJay Services account or complete customer purchases.
  • To communicate with our customers; to inform customers and users of products, programs, services and promotions.
  • To send customers information regarding the BluJay Services and issues specifically affecting BluJay Services
  • To respond to reviews, comments, or other feedback provided to us.
  • To support and personalize our Services, websites, mobile services, and advertising.
  • To protect the security and integrity of our Services, content, and our business.
  • To provide support; for other business purposes, such as benchmarking, data analysis, audits, developing new products, enhancing the BluJay Services, facilitating product, software and applications development, improving our services, conducting research, analysis, studies or surveys, and identifying usage trends.
  • To meet our contractual requirements, to comply with applicable legal or regulatory requirements and our policies, to protect against criminal activity, claims and other liabilities.
  • For any other lawful purpose for which the information is provided.

We may use, process, transfer, and store any data in an anonymous, aggregated manner. We may combine personal information with other information, collected online and offline, including information from third party sources.

In addition, we, and customers using our Services, may also use cookies and other tracking technologies such as beacons, tags, scripts and other similar technologies, including cross-device tracking.  The purposes of such use may include benchmarking, metrics, analytics, quality assessment and other lawful purposes. Please visit our Cookies Policy for more information on these practices.

We, and our customers, may also use information in other ways with consent or as permitted by applicable law.

Aggregate Information. To the extent permitted by applicable law, we may use, process, transfer, and store any data about individuals and about customers or partners in an anonymous (or pseudonymous) and aggregated manner. We may combine personal information with other information, collected online and offline, including information from third party sources. We may also use information in other ways with consent or as permitted by applicable law. By using the BluJay Services, our customers and partners agree that we are hereby licensed to collect, use, share and store anonymized (or pseudonymized) aggregated data collected through the BluJay Services for benchmarking, analytics, metrics, research, reporting, machine learning and other business purposes.

Automated Decisions. To the extent permitted by applicable law, we may collect data in an automated manner and make automated decisions, including using machine learning algorithms, about individual users of the BluJay Services in order to provide or optimize the BluJay Services offered and/or delivered, for security or analytics purposes, and for any other lawful purpose. To the extent permitted by applicable law, we may use automated decisions, for example, to display advertisements and offers based on the individual’s preferences.


SHARING OF INFORMATION
To the extent permitted by applicable law, BluJay Solutions may share and disclose information, including personal information, as set forth below:

  • Customers. We may share information with our customers and their service providers and other platforms that may assist those customers.
  • Affiliates and Agents. We may share information with our affiliates or any business partners or agents acting on our behalf.
  • Service Providers. We may share information with our service providers, agents, vendors and other third parties we use to support and advertise the BluJay Services and our business. We share personal information with such third parties to the extent necessary to provide services to us, and pursuant to binding contractual obligations.
  • Advertising and Marketing. To the extent permitted by applicable law, we may share information with third parties for marketing, advertising, promotions, contests, or other similar purposes. If required by applicable law, we will share such data for advertising and marketing purposes only in an aggregate, anonymous, and de-identified manner.
  • Mergers, Acquisitions, Divestitures. We may share, disclose or transfer information to a buyer, investor, new affiliate, or other successor in the event BluJay Solutions, or any affiliate, portion, group or business unit thereof, undergoes a business transition, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of any assets of BluJay Solutions or any affiliates or during steps in contemplation of such activities (e.g., negotiations and due diligence).
  • Law Enforcement and National Security. We may share information with legal, governmental, or judicial authorities, as instructed or required by those authorities or applicable laws, or to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, government request, regulatory request, law enforcement or national security investigation, or as otherwise required or authorized by law.
  • Protection of Rights, Property or Safety. We may also share information if, in our sole discretion, we believe disclosure is necessary or appropriate to protect the rights, property or safety of any person, or if we suspect fraud or other illegal activity,

BluJay Solutions may also disclose personal data for other purposes or to other third parties when an individual has consented to or requested such disclosure, or where a customer has obtained permission from such individual, or where such disclosure is otherwise legally permitted for legitimate business purposes, and, for customer data, only with such customer’s authorization or otherwise in accordance with BluJay Solutions’ agreement with such customer.

DATA RETENTION 
To the extent permitted by applicable law, we may retain information for as long as the account of the customer for whom we collected the information is active, for at least twenty-four (24) months thereafter, or as long as is reasonably necessary to provide the BluJay Services or as needed for other lawful purposes. We may retain cached or archived copies of information. We may retain anonymized or pseudonymized, aggregated data indefinitely, to the extent permitted under applicable law. We may be required to retain some data for a longer period of time because of various laws and regulations or because of contractual obligations. We also will retain information as long as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

CHILDREN’S PRIVACY
The BluJay Services are not intended for children under 13 years of age (and for European residents, for children under 16 years of age per our European Privacy Policy). We do not knowingly collect information from children under the age of 13 (or, for European residents, under 16). If we learn we have collected or received personal information from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child, please contact us as set forth below.

CHOICES AND OPT-OUT
To the extent required by applicable law, or in our discretion otherwise, we will allow our customers, partners and other individuals to limit use and sharing of personal information that complements our products and services. If you have questions about your choices or concerns about use or sharing of your personal information, please contact us as set forth below.

Please note that these choices do not apply to communications primarily for the purpose of administering order completion, contracts, support, product safety warnings, driver updates, or other administrative and transactional notices.

If a customer, partner or an individual no longer wishes to receive marketing-related communications from us, they may opt out by following the “unsubscribe” instructions in the latest such message received or by contacting us as indicated below.

SECURITY 
The security of personal information that BluJay Solutions collects and that is collected using our Services is important to us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, BluJay Solutions utilizes appropriate physical, technical and administrative procedures to safeguard the information we collect. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Therefore, despite our efforts, we cannot guarantee its absolute security. We do not warrant or represent that personal information about you will be protected against, loss, misuse, or alteration by third parties.

Where required under applicable law or by contract, we will notify the appropriate parties of any loss, misuse or alteration of personal information that may affect the affected individuals so that such parties or individuals can take the appropriate actions for the due protection of your rights.  If such personal information is information of a BluJay customer, we will notify such customer and coordinate with them regarding any notices to particular individuals.

THIRD PARTY LINKS
The BluJay Services may provide links to third-party websites for convenience and informational purposes only. If you access those links, you will leave the BluJay Services and be subject to the privacy policy of those companies. BluJay Solutions does not control those sites or services and we encourage you to review their privacy practices before submitting any personal information. We do not endorse or make any representations about third-party websites or other services.

INTERNATIONAL DATA TRANSFERS
The BluJay Services may be provided using resources and servers located in various countries around the world, including the United States and other countries. Therefore, personal information about individuals or customers may be transferred, processed and stored outside the country where the BluJay Services are used, including to countries outside the European Union (“EU”), European Economic Area (“EEA”) or Switzerland, where the level of data protection may not be deemed adequate by the European Commission.

CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, 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 per calendar year, information about customer information we have shared, if any, with other businesses for such other businesses’ own direct marketing uses. If applicable, this information would include the categories of resident information and the names and addresses of those businesses with which we shared such resident information for the immediately prior calendar year. To obtain this information, please contact us as indicated below. Please include sufficient personal identification information so that we can process the request, including that you are a California resident.

CANADIAN RESIDENTS
Canadian residents may have additional rights under Canadian law.

You, and we, confirm that it is our wish that this document and all other related documents be drawn up in English. Tous les parties reconnaissent avoir exigé la rédaction en anglais du présent document ainsi que tous les documents qui s’y rattachent.

EMPLOYEES AND CONTRACTORS; JOB APPLICANTS
Employees and Contractors:  If you are an employee or contractor of BluJay Solutions, please contact the Human Resources Department for our privacy policy for employees and contractors.  This Privacy Policy is separate from our internal privacy policy for employees and contractors.

Job Applicants:  In connection with a job application or inquiry, you may provide us with data about yourself, including your educational background or résumé and other information, including your ethnicity where required or permitted by law. We may use this information throughout the BluJay Solutions affiliated entities for the purpose of employment consideration. We may keep the information for future consideration unless you direct us not to do so.

Commitment: BluJay Solutions commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.


QUESTIONS, COMPLAINTS AND DISPUTES 
In compliance with the Privacy Shield Principles, BluJay Solutions commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact BluJay Solutions at:

GlobalPrivacyOffice@blujaysolutions.com

BluJay Solutions
Attn: Privacy Administrator
915 E 32nd St Ste B
Holland, MI 49423, USA

If you are in the European Union, European Economic Area or Switzerland, please see our European Privacy Policy for additional contact information. All complaints will be evaluated and a reply will be sent as soon as appropriate.

BluJay Solutions has further committed to refer unresolved Privacy Shield complaints to JAMs, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit JAMs complaint handling page: https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint.  The services of JAMs are provided at no cost to you.

CLASS ACTION WAIVER
YOU AND WE AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR OUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

DISPUTE RESOLUTION
Except as otherwise expressly provided above, or in our European Privacy Policy or otherwise required by applicable law, you agree that the exclusive jurisdiction of any actions arising out of, relating to, or in any way connected with, this Privacy Policy, shall be in the state or federal courts, as applicable, located in the City of Boston or Suffolk County, Massachusetts. Any dispute, controversy, or claim arising out of or relating to this Privacy Policy or the collection, use, storage or transfer of any of your information or data, including, but not limited to, the arbitrability of the matter or the formation, interpretation, scope, applicability, termination, or breach of this Privacy Policy, shall be referred to and finally determined by arbitration in accordance with the JAMS Streamlined Arbitration Rules and Procedures, or JAMS International Arbitration Rules, if the matter is deemed “international” within the meaning of that term as defined in the JAMS International Arbitration Rules. The arbitration shall be administered by JAMS, shall take place before a sole arbitrator, and shall be conducted in Boston, Massachusetts. If the JAMS International Arbitration Rules apply, the language to be used in the arbitral proceedings will be English. Judgment upon the arbitral award may be entered by any court having jurisdiction. This section shall apply to and require arbitration of all disputes, controversies, and claims, regardless of whether such disputes, controversies, or claims concern a single individual, entity, or other person, multiple individuals, entities, or other people, or classes of individuals, entities, or other people. You hereby consent to receive service of process by electronic means or social media to the extent allowed by the applicable court. This constitutes express agreement of the parties regarding your consent pursuant to United States Federal Rule of Civil Procedure 5(b)(2)(E) and any applicable state (or other jurisdiction) equivalent.

UPDATES AND CHANGES 
We may update this Privacy Policy at any time in our sole discretion to reflect changes to our information and privacy practices by posting a revised version of this Privacy Policy on this page or in the BluJay Services, or with any notice to individual users if required by applicable law. Continued use of the BluJay Services after any such modifications constitutes acceptance to any such modified Privacy Policy. We encourage periodic review of this page for the latest information on our privacy practices. The date of last revision is shown at the top of this Privacy Policy.

LIABILITY
If you suffer damage as a result of any breach of the obligations referred to in this Privacy Policy you may be entitled to receive compensation for the damage suffered.

ONWARD TRANSFER LIABILITY
BluJay will process data for the limited and specified purposes consistent with the consent provided by an individual and if BluJay makes a determination that it can no longer meet this obligation BluJay shall cease processing the data and take reasonable and appropriate steps to remediate. When transferring personal data to a third party acting as an agent, BluJay shall: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with the organization’s obligations under the Principles; (iv) require the agent to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department upon request.

We are responsible for the processing of personal data we receive under the Privacy Shield Framework and subsequently transfer to a third party agent, and may be liable for onward transfers in violation of the Privacy Shield Principles.

EUROPEAN PRIVACY POLICY

The following European Privacy Policy applies to residents of the European Union, the European Economic Area and Switzerland.

Personal Data and Processing. For the purposes of this European Privacy Policy:

Personal Data” means “any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person”; and

Processing” means “any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.”

EU-U.S. and Swiss-U.S. Privacy Shield Notice. BluJay Solutions complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  BluJay Solutions has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.  Our certification is available here. We may also process personal data submitted relating to individuals in Europe via other compliance mechanisms, including use of the European Union Standard Contractual Clauses.

Purposes and Legal Bases for Processing Personal Data. BluJay Solutions Processes data for the purposes as set forth in our BluJay Solutions Privacy Policy, including to provide the BluJay Services and as explained in the Use of Information and Sharing of Information sections. To fulfill these purposes, BluJay Solutions may access data, including Personal Data, to provide the BluJay Services, to correct and address technical or service problems, or in response to contractual requirements. Please see our BluJay Solutions Privacy Policy Information We May Collect and Data Retention sections for additional details on how we collect, use, disclose and share data, make automated decisions, and retain data, including Personal Data, about individual users or customers.

Our legal bases for the processing of Personal Data are: (i) consent and/or (ii) any other applicable legal bases, such as our legitimate interest in engaging in commerce, supporting internal business functions, offering products and services of value to the customers of the BluJay Services, preventing fraud, ensuring information and network security, direct marketing and advertising, and complying with industry practices.

Additional Rights for European Residents. Residents of the EU or a country following substantially similar legislation regarding the protection of personal data, may have one or more of the following additional rights:

Access. To request a copy of the Personal Data we have collected about you by contacting us.

Rectification & Erasure. To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.

Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.

Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration.

Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.

Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including processing related to existing contracts for our products and services.

Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority (“DPA”).

Commitment: BluJay Solutions commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

To exercise any of the above listed rights, please contact us as set forth below and provide sufficient details so that we can respond appropriately. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify the identity of the individual submitting a request before we can address such request. Because BluJay Solutions has limited ability to access data our customers collect and process through the BluJay Services, and because such customers generally have the direct relationship with individuals from whom they collect data, please provide the name of the BluJay Solutions customer believed to have collected or Processed the Personal Data in question through the BluJay Services (if applicable). We will refer the request to that customer and, if so, will support them in responding to the request. Please note that, for BluJay Solutions customers, certain information may be reviewed, corrected and updated by logging into the BluJay Services account and editing the profile information.

Questions and Complaints. Residents of a country participating in the Privacy Shield Framework may direct any questions or complaints concerning our Privacy Shield compliance to our Privacy Shield and Data Protection Contact. We will work with you to resolve your issue.

In compliance with the Privacy Shield Principles, BluJay Solutions commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact BluJay Solutions at:

If you have any questions or comments regarding this Privacy Policy or our collection, use, sharing or storage of your information, please contact us by email or writing us at:

GlobalPrivacyOffice@blujaysolutions.com

BluJay Solutions
Attn: Privacy Administrator
915 E 32nd St Ste B
Holland, MI 49423, USA

BluJay Solutions has further committed to refer unresolved Privacy Shield complaints to JAMs, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit JAMs complaint handling page/link https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint.  The services of JAMs are provided at no cost to you.

If neither BluJay Solutions nor our independent dispute resolution provider resolves your complaint, you may have the possibility to invoke binding arbitration through the Privacy Shield Panel. However, prior to initiating such arbitration, a resident of a country participating in the Privacy Shield Framework must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our designated independent dispute resolution provider; and (3) contact the U.S. Department of Commerce (either directly or through a European DPA) and afford the Department of Commerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.

U.S. Federal Trade Commission Enforcement. BluJay Solutions’ commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Compelled Disclosures. BluJay Solutions may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Privacy Shield and Data Protection Contact. Unless otherwise specified, the data controller of data Processed about individual users of the BluJay Services is the BluJay Solutions customer for whom such Services are provided and BluJay Solutions is the processor of such data for such customer. In certain cases, BluJay Solutions may also be the controller of aggregated, anonymous or pseudononymous data relating to the BluJay Services. Our Privacy Shield and Data Protection Contact for personal information collected, used, shared or stored by BluJay Solutions in connection with the BluJay Services is as follows:

GlobalPrivacyOffice@blujaysolutions.com

BluJay Solutions
Attn: Privacy Administrator
915 E 32nd St Ste B
Holland, MI 49423, USA

Liability. If you suffer damage as a result of any breach of the obligations referred to in this Privacy Policy you may be entitled to receive compensation for the damage suffered.


COOKIE POLICY & CROSS-DEVICE TRACKING NOTICE

Date Last Revised: May 29, 2018

WHAT ARE COOKIES?
Cookies are small text files which are stored on your computer or mobile device when you visit some websites. They enhance your browsing experience in various ways, such as remembering your preferences, displaying relevant content and ensuring pages function as intended.

Want to know more about cookies? The Interactive Advertising Bureau has produced a guide which explains how cookies work and how they are managed – visit http://www.allaboutcookies.org/ to read more.

COOKIES WE USE

Here’s a list of the cookies we use and what they’re for:

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Cookie name Domain source Category of cookie Benefit Lifespan
_icl_current_language www.blujaysolutions.com Strictly Necessary Stores a language value for the website to enable translated content. 1 day
X-Mapping-xxxxxxxx www.blujaysolutions.com Strictly Necessary Used to route data and page requests to the correct server where a site is hosted on multiple servers. End of browser session

Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.

All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Cookie name Domain source Category of cookie Benefit Lifespan
_gid blujaysolutions.com Performance Used to calculate visitor, session and campaign data for the sites analytics reports. 1 day
_ga blujaysolutions.com Performance Used to calculate visitor, session and campaign data for the sites analytics reports. 2 years
_gat blujaysolutions.com Performance Used to throttle request rate. 1 minute
_mkto_trk info.blujaysolutions.com Performance Used to track which pages the user has visited, in what sequence, and for how long. 2 years
_pk_id* blujaysolutions.com Performance It is used to help website owners track visitor behavior and measure site performance. 2 years
_pk_ses* blujaysolutions.com Performance It is used to help website owners track visitor behavior and measure site performance. 30 minutes

Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

EXTERNAL LINKS
On our website you may find links to external websites – these are provided for your convenience, but we don’t endorse, guarantee or monitor products, services, or views which they offer or express. Please be aware that these websites should be covered by their own cookie policies.

OTHER TRACKING TECHNOLOGIES
In addition to cookies, we may also use other tracking technologies such as beacons, tags, scripts and other similar technologies:

  • Web beacons. Web beacons, also known as clear GIFs or single-pixel GIFs, are small image files that we, our service providers and partners, our customers and their agents place on our website and our emails. Working in conjunction with cookies, web beacons allow us to accurately count the number of unique users who have visited a specific page on the website, or opened or acted upon an email. This information allows us to measure the performance of our website and our email campaigns
  • Log Files. As is true of most online services, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, device type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. IP address is a number that is automatically assigned to the computer by an Internet Service Provider (ISP), and in many cases, IP addresses are shared by multiple people. This number is identified and logged automatically in our server log files whenever you use the BluJay Services, along with the time(s) of the visit(s) and the page(s) visited. We may combine this automatically collected log information with other information we collect. We do this to provide analytics data to our BluJay Services customers, to improve the functionality of the BluJay Services and for the other purposes described in our Privacy Policy.
  • Do Not Track. BluJay Services do not currently recognize if a browser sends a “do not track” signal or similar mechanism to indicate the user does not wish to be tracked or receive interest-based ads.
  • Analytics. We, and our customers, their partners and agents, and other third parties, may use third party analytics such as Google Analytics or similar analytics services. For information on how Google processes and collects information and opt out options, please see https://tools.google.com/dlpage/gaoptout.

CROSS-DEVICE TRACKING
When users of the BluJay Services use devices, we may receive information about their devices, including a unique identifier for each the device. We and our service providers and third parties we collaborate with may use cross-device/cross-context tracking. For example, the individual might use multiple browsers on a single device, or use various devices (such as desktops, smartphones, and tablets), which can result in the individual having multiple accounts or profiles across these various contexts and devices. Cross-device/cross-context technology may be used to connect these various accounts or profiles and the corresponding data from the different contexts and devices.

COOKIE SETTINGS
You can control how cookies are placed on your computer or mobile device by changing your internet browser settings (via the ‘Tools’ menu).

If you choose to block all cookies, you may experience difficulty when using some online services. Some website functionality may not perform as intended, your preferences won’t be stored and you may not receive advertisements about offers which would be relevant to your interests/needs.

You can however allow cookies from specific websites by making them ‘Trusted websites’. Please refer to your internet browser provider for further guidance.

Please note: if you use multiple internet browsers/computers/mobile devices, you’ll need to update your settings on each in order to disable cookies completely should you wish to do so.

You can delete any existing cookies from your browser, and if you completely disable cookies we won’t gather any further information, but we may still use information collected in the past.

Want to know more about cookies? The Interactive Advertising Bureau has produced a guide which explains how cookies work and how they are managed – visit http://www.allaboutcookies.org/ to read more. All information is encrypted for security.

COOKIE POLICY CHANGES
BluJay Solutions may change this cookie policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this cookie policy occasionally so you’re aware of any changes. By using our website you accept this policy and that we may store and access cookies on your device.

This cookie policy is published by BluJay Solutions Inc., 915 E 32nd St Ste B, Holland, MI 49423, USA.