JOJA PRIVACY POLICY

Effective Date: February 1, 2022 

This Privacy Policy (“Policy”) describes how Joja Life, LLC and its affiliates (“Joja,” “we,” “us,” and “our”) collects, uses, and discloses information that we obtain about visitors to our website, Joja.com (the “Site”), and the services available through our Site (collectively, the “Services”). 

By visiting the Site or using any of our Services, you agree that your information will be handled as described in this Policy. Your use of our Site and Services is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Joja Terms of Use are incorporated by reference into this Policy. 

Information We Collect About You 

We collect information about you directly from you, from third parties, and automatically through your use of our Services. 

Information We Collect Directly From You. We may collect certain information directly from you when you use our Services, including information that you provide when you visit our Site, access our content, enroll in mailing lists or text message campaigns, view or purchase a product or service, apply for a job, contact customer support, or otherwise communicate or transact with us through the Services. The categories of information we collect directly from you include the following: 

• Contact Data, including your first name and last name, email address, postal address, phone number, and similar contact data. 
• Content, including content within any messages you send to us (such as when you fill out the “Contact Us” form or send questions to customer support).
• Demographic Data, including your age, gender, and country of residence.
• Payment Data, including data necessary to process your payments if you make a purchase through the Services, such as your credit or debit card number, financial account information, or other payment information.
• Contests/Promotions, including information necessary for the administration of certain promotional events.
• Employment and Education Data, including your employment and education history, resume, cover letter, transcript, writing samples, and references as necessary to consider you for job openings.

You may choose to voluntarily submit other information to us through the Services that we do not request, and, in such instances, you are solely responsible for such information.  

Information We Collect from Other Sources. We also collect information from other sources. To the extent we combine information from other sources with information we have collected about you through the Services, we will treat such information in accordance with this Policy, plus any additional restrictions imposed by the source of the data, if any. The categories of sources from which we collect information include: 

• Affiliates
• Social networks with which you interact, such as when you reference Joja or our Services, or grant Joja permission to access your data on one or more of these services.
• Partners with which we offer co-branded services or products, sell or distribute our products, or engage in joint marketing activities.
• Publicly available sources, including data in the public domain and data available in open government databases.

Information We Collect Automatically. We automatically collect information when you use our Services, such as your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Services; and the referring URL, or the webpage that led you to our Services. 

Information We Collect From Cookies and Similar Technologies. We, and our service providers and business partners, collect information using cookies, pixel tags, or similar technologies. Our service providers and business partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. For more information, please see the section on “Our Use of Cookies and Other Tracking Mechanisms,” below. 

How We Use Your Information 

We use the information we collect about you for our legitimate interests and business and commercial purposes in accordance with the practices described in this Policy. Our purposes for using information include: 

• To provide our Services to you and fulfill your orders. 
• To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes. 
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experience while using the Services. 
• For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you with information we think may interest you. We may also use the information that we learn about you to assist us in advertising our services on third-party websites and in other forums.
• To better understand how users access and use our Services. For example, we will evaluate which features of our Site are most (or least) used by Site visitors, and we will use this information. 
• For research and analytics purposes. 
• To administer surveys and questionnaires. 
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes. 
• Where we believe necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to safety of any person or violations of our Terms of Use or this Policy. 
• For internal business purposes. 
• To fulfill any other purpose at your direction. 
• With notice to you and your consent. 
• Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose, except as prohibited by applicable law.

How We Share the Information We Collect 

We may share your information as follows: 

• Related Entities. We may disclose the information we collect about you to our related entities, including our parents, affiliates, or subsidiaries. However, if we do so, their use and disclosure of your information will be subject to this Policy.

• Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. These service providers include Shopify, to power our online store – you can read more about how Shopify uses your information here: https://www.shopify.com/legal/privacy. 

• Vendors and Other Parties. We may disclose the information we collect about you to third parties, such as business partners and commercial vendors that we use to implement or provide our Services. These parties may act as our service providers, or in certain contexts, independently decide how to process your information.

• Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our services, or engaging in joint marketing activities. 

We may also disclose your information in the following circumstances: 

• Public Forums. We disclose information you make public, such as when you post information and materials on our message boards and forums. When you post information in a public forum it becomes public information, and you are solely responsible for that information. Once you have posted information, you may not be able to edit or delete such information, subject to the additional rights set out in the “Children” section (if you are under 18 years old) below.

• Promotions. We offer sweepstakes, contests, surveys, and other promotions (each, a “Promotion”) jointly sponsored or offered by separate entities that may require submitting information. If you voluntarily choose to enter a Promotion, we share information as set out in the official rules that govern the Promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.

• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may share certain of your information with lenders, auditors, and third party advisors, including attorneys and consultants.

• Legal Disclosure. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.

• Aggregate and De-Identified Information. We may share aggregate, anonymized, or de-identified information about users with third parties for any lawful purpose.

• Facilitating Requests. We share information at your request or direction.

• Consent. We may share information with notice to you and your consent.

Our Use of Cookies and Other Tracking Mechanisms

We and our third party vendors use cookies and other tracking mechanisms to track information about your use of our Site and Services. We may combine this information with other information we collect about you (and our third party vendors may do so on our behalf). 

• Cookies. A cookie is a small file placed on the hard drive of your computer. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our Services and expire when you close your browser. Persistent cookies help with personalizing your experience and supporting security features. Additionally, persistent cookies allow us to bring you advertising on and off the Services. Persistent cookies may remain on your device for extended periods of time. You may refuse to accept browser cookies by activating the appropriate setting(s) on your browser. Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of the Services to their fullest potential. 
• Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags) to among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party vendors also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. 
• Third Party Analytics. We use automated devices and applications provided by third parties, such as Google Analytics, to evaluate usage of our Site. We also may use other, third-party provided analytic means to evaluate our Site. We use these tools to help us improve our Site, performance, and user experiences. The entities providing these tools may use cookies and other tracking technologies to perform their services. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout, by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/, or downloading the Google Analytics Opt-out Browser Add-on.  
• Third Party Ad Networks. We use third party advertising partners to show you ads that we think may interest you. Most of these third party advertising partners are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com. 

Third Party Links

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites. 

Security of My Information 

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. 

Marketing Communications

• SMS and Email. Where lawful to do so, and subject to your consent where required, we may communicate with you by SMS and email to tell you about our products and services. If you wish to opt-out of receiving marketing communications, please use the “unsubscribe” link provided in our emails or text the STOP number in our SMS, or otherwise contact us directly and we will stop sending you communications as soon as reasonably possible, but no later than 10 business days from receipt of your request. 

• Promotional Email. We may send periodic promotional or informational emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about any services you have requested or received from us. 

Children

Our Services are intended for a general audience and are not directed at children under the age of 13. We do not knowingly collect, store, share, or use the information of children under 13 years old. If we discover that a child under the age of 13 has provided us with information, we will delete such information from our systems. 

If you are a California resident under 18 years old and you are registered with the Services, you can ask us to remove content or information you have posted to the Services. Email us at info@joja.com with “California Under 18 Content Removal Request” in the subject line and tell us what you want removed. We may require additional information from you to allow us to verify your identity as well as details about where the content is posted. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

International Transfers 

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Services from outside of the U.S., please be aware that information collected through the Services may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may differ from those of your country of residence. Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. 

Contact Us 

If you have questions about the privacy aspects of our Site or Services, or would like to make a complaint, please contact us at info@joja.com or by mail using the details provided below. 

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site or sending you an email.