Last Updated: 7 February 2024

Jacobi, Inc. and its affiliates (“Jacobi,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites (including www.jacobistrategies.com) or services that link to this Privacy Policy (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information from users of our Services. As used in this Privacy Policy, “Personal Information” means any information or opinion relating to an identified or reasonably identifiable individual. By using our Services, you agree to the collection, holding, use, and disclosure of your Personal Information as described in this Privacy Policy.

INFORMATION WE COLLECT AND HOLD

We may collect and hold a variety of information from or about you or your devices from various sources, as described below.

If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.

A. Information You Provide to Us

Registration. When you register for an account to use our Services, we ask you for your Personal Information, including your name, email address, and password.

Request a Demo. If you schedule a demo of our Services, we will collect your Personal Information, including your name, email address, company name, phone number, country, and any additional information you choose to provide.

Communications. If you contact us directly, we may receive additional Personal Information about you. For example, when you contact us for support, we will receive your name, email address, and any additional information you choose to provide. If you subscribe to our newsletter, we will receive your name and email address.

Careers. If you decide to apply for a job with us, you may submit your contact information and your resume online. We will collect the Personal Information you choose to provide us as part of your job application, such as your contact information, current employment information, and other information you choose to submit with your application and on your resume. If you apply for a job with us through a third-party platform (such as Seek or LinkedIn), we will collect any information you make available to us through such third-party platform.

B. Information We Collect and Hold When You Use Our Services

Location Information. When you use our Services, we may infer your general location information. For example, your IP address may indicate your general geographic region.

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type, operating system version, and device identifiers.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, such as the pages or other content you view, the searches you conduct, telemetry data, and the dates and times of your visits.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

Information from Cookies and Similar Technologies. We and our third-party partners may collect Personal Information using Cookies. Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies“) to collect information about your browsing activities and to distinguish you from other users on the Services. This aids your experience when you use the Services and also allows us to improve the functionality of the Services. Cookies can be used for performance management, collecting information on how the Services are being used for analytics purposes. They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords and log-in details. We may also use pixel tags and web beacons on the Services. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. Below is an overview of the types of Cookies we and third parties may use to collect Personal Information.

• Strictly Necessary Cookies. Some Cookies are strictly necessary to make the Services available to you. We cannot provide you with the Services without this type of Cookies.
• Functional Cookies. Functional Cookies are used to recognize you when you return to the Services. This enables us to adapt our content for you and remember your preferences. For example, we use functional Cookies to remember your choice of language or region.
• Analytical or Performance Cookies. We also use Cookies for website analytics purposes in order to operate, maintain and improve the Services. We may use our own analytics Cookies or use third-party analytics providers such as Google Analytics, Hotjar, LinkedIn, Hubspot and NextRoll to collect and process certain analytics data on our behalf. These providers may also collect information about your use of other websites, apps, and online resources. See table below for further information on analytical or performance Cookies Jacobi may use.
• Advertising Cookies. We may enable third-party tracking mechanisms to collect data over time and across external websites for use in interest-based advertising. For example, third parties may use the fact that you visited the website to send you online ads for Jacobi products on third party websites. In addition, our third-party advertising partners might use information about you to send you targeted advertisements based on your online behavior. See table below for further information on Advertising Cookies Jacobi may use.

Provider	Cookie Type	Name	Description	Expires
Google LLC	Analytical or performance cookies	_ga	Used by Google Analytics to distinguish users.	2 years
Google LLC	Analytical or performance cookies	_gat_gtag_UA_66023228_1	Used to throttle request rate.	1 minute
Google LLC	Analytical or performance cookies	_gid	Used by Google Analytics to distinguish users.	24 hours
Hotjar Ltd	Analytical or performance cookies	_hjSessionUser_2688509	Set when a user first lands on a page. Persists the Hotjar User ID which is unique to that site. Ensures data from subsequent visits to the same site are attributed to the same user ID.	365 days
Hotjar Ltd	Analytical or performance cookies	_hjAbsoluteSessionInProgress	Used to detect the first pageview session of a user.	30mins
Hotjar Ltd	Analytical or performance cookies	_hjIncludedInPageviewSample	Set to determine if a user is included in the data sampling defined by your site’s pageview limit.	30mins
Hotjar Ltd	Analytical or performance cookies	_hjSession_2688509	Holds current session data. Ensures subsequent requests in the session window are attributed to the same session.	30 mins
Hotjar Ltd	Analytical or performance cookies	_hjFirstSeen	Identifies a new user’s first session.	session
Hotjar Ltd	Analytical or performance cookies	_hjIncludedInSessionSample	Set to determine if a user is included in the data sampling defined by your site’s daily session limit.	30 minutes
Hubspot Inc	Analytical or performance cookies	__cf_bm	This cookie is set by HubSpot’s CDN provider and is a necessary cookie for bot protection.	30mins
Hubspot Inc	Analytical or performance cookies	__hstc	The main cookie for tracking visitors.	6 months
Hubspot Inc	Analytical or performance cookies	__hssrc	Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser.	session
Hubspot Inc	Analytical or performance cookies	__hssc	This cookie keeps track of sessions.	30 minutes
Hubspot Inc	Analytical or performance cookies	hubspotutk	This cookie keeps track of a visitor’s identity. It is passed to HubSpot on form submission and used when deduplicating contacts.	6 months
LinkedIn	Analytical or performance cookies	AnalyticsSyncHistory	Used to store information about the time a sync took place with the lms_analytics cookie	30 days
LinkedIn	Analytical or performance cookies	lidc	To facilitate data center selection	24 hours
Google LLC	Advertising	NID	The purpose of this cookie is to store information about your preferences.	6 months
Google LLC	Advertising	1P_JAR	To provide ad delivery or retargeting.	1 month
LinkedIn	Advertising	UserMatchHistory	LinkedIn Ads ID syncing	30 days
LinkedIn	Advertising	li_sugr	Used to make a probabilistic match of a user’s identity outside the Designated Countries	90 days
LinkedIn	Advertising	bcookie	Browser Identifier cookie to uniquely indentify devices accessing LinkedIn to detect abust on the platform	2 years
LinkedIn	Advertising	lang	Used to remember a user’s language setting to ensure LinkedIn.com displays in the language selected by the user in their settings	Session
NextRoll Inc	Advertising	__ar_v4	this cookie is associated with AdRoll’s attribution and tracking efforts which provides insights into the effectiveness of campaigns.	12 months
NextRoll Inc	Advertising	__adroll_bounced3	Non tracking cookie for users redirected through Safari bounce.	5 years
NextRoll Inc	Advertising	__adroll_consent	This cookie is used to identify the visitor across visits and devices.	12 months
NextRoll Inc	Advertising	^__adroll_fpc$	This is a “first-party cookie” that is set by AdRoll which tracks user interactions and engagement with ads and services.	12 months

Where required by applicable law, we will obtain your consent to use Cookies. You can find more information about your rights and choices, and how to block the use of certain Cookies in the section Your Rights and Choices below.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

Our site uses technologies of third-party partners [such as NextRoll] to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, [NextRoll/these partners] collect information about your activity on our site(s) to enable us to:

• measure and analyze traffic and browsing activity on our site(s);
• show advertisements for our products and/or services to you on third-party sites;

We may share data, such as hashed email (encrypting an email address by giving it a unique 32, 40, or 64-character code) derived from emails or other online identifiers collected on our site(s) with [NextRoll/ our advertising partners]. This allows our partners to recognize and deliver your ads across devices and browsers. To read more about the technologies used by [NextRoll/our partner] and their cross device capabilities please refer to NextRoll’s Privacy Notice.

C. Information We Receive from Third Parties

Partners. We may receive Personal Information about you from third parties such as data or marketing partners and combine it with other information we have about you.

HOW WE USE THE INFORMATION WE COLLECT AND HOLD

We use the Personal Information we collect and hold:

• To provide, maintain, debug, improve, and enhance our Services;
• To understand and analyze how you use our Services, and develop new products, services, features, and functionalities;
• To understand and analyze usage patterns;
• To process your job application;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• [To undertake marketing activities including direct marketing by us];
• To find and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the Personal Information is collected.

LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION

If you are located in the European Economic Area (“EEA“) or the United Kingdom (“UK“), we only process your Personal Information when we have a valid “legal basis”, including as set forth below.,

• Consent. You have consented to the use of your Personal Information. For example, we may process your Personal Information to send you marketing communications or to use Cookies where you have consented to such use.
• Contractual Necessity. We need your Personal Information to provide you with our Services. For example, we may need to process your Personal Information to respond to your inquiries or requests.
• Compliance with a Legal Obligation. We have a legal obligation to use your Personal Information. For example, we may process your Personal Information to comply with tax, labor, and accounting obligations.
• Legitimate Interests. We or a third party have a legitimate interest in using your Personal Information. Specifically, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

HOW WE SHARE THE INFORMATION WE COLLECT AND HOLD

We do not share or otherwise disclose Personal Information we collect from you and hold except as described below or otherwise disclosed to you at the time of the collection.

Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may share any Personal Information we receive with vendors and service providers retained in connection with the provision of our Services.

Marketing. We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect Personal Information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may disclose and transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.

Consent. We may also disclose Personal Information from or about you or your devices with your permission.

YOUR RIGHTS AND CHOICES

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, if you are a registered user you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

If you choose not to provide us with the information we collect, some features of our Services may not work as intended.

How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Services. By using the Services, you consent to our use of Cookies and our processing of Personal Information collected through such Cookies, in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse the Services using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of the Services may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

Our partners [such as NextRoll] may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third party tools to decline the collection and use of information for the purpose of serving you interest based advertising

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform: http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Your European Privacy Rights. If you are located in the EEA or the UK, you have the additional rights described below:

• You may request access to the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• You may withdraw any consent you previously provided to us regarding the processing of your Personal Information at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Your Australian Privacy Rights. If you are located in Australia, you have the additional rights described below:

• You may request access to the Personal Information we maintain about you and ask us to update and correct inaccuracies in your Personal Information. If you are not satisfied with how we handle your Personal Information, you can lodge a complaint in writing. Jacobi receives mail at any of the addresses given in the section entitled ‘Contact Information’ at the end of this Privacy Policy, or by email sent to [email protected]. In addition, you also have the right to lodge a complaint with the Office of the Australian Information Commissioner.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services“). We are not responsible for the privacy practices of these Third-Party Services. Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services. We encourage you to read the privacy policies of these Third-Party Services before you provide them with your Personal Information.

RETENTION

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when your Personal Information is no longer necessary for the purposes for which we process it unless we are required by law to keep your Personal Information for a longer period. When determining the specific retention period, we consider various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

SECURITY

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information.

INTERNATIONAL VISITORS

Our Services are hosted in Australia, Europe, the United Kingdom, and the United States (“U.S.”). Laws governing data collection and use may differ from one another. If you choose to use our Services, then please note that you may be transferring your Personal Information outside of one of these regions to another for storage and processing.  We may transfer Personal Information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved Standard Contractual Clauses, as needed to perform our services that you have requested from us, or with your consent. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services.  By providing any information, including Personal Information, on or to our Services, you consent to such transfer, storage, and processing.

We may transfer Personal Information from Australia to the United Kingdom, the United States, and other countries where we obtain an enforceable contractual commitment from the overseas recipient to comply with the Australian Privacy Principles. 

The countries to which your Personal Information may be transferred to or stored in include: Australia, Canada, Czech Republic, Estonia, France, Germany, Ireland, Netherlands, Singapore, Switzerland, the United Kingdom, the U.S., and any other countries where our service providers are based.      

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no parts of our Services are directed to children. If you learn that a child has provided us with information in violation of this Privacy Policy, please alert us [email protected].

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through the Services, we will attempt to notify you through the Services, by email, or by other means.

CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at [email protected] or write to us at:

Jacobi, Inc.
44 Montgomery Street, Suite 1404
San Francisco, CA 94104

Jacobi Strategies Pty Ltd
Level 15, 111 Eagle Street
Brisbane, QLD 4000

Jacobi EMEA Limited
5 New Street Square
London EC4A 3TW