Privacy Policy

Last updated: April 19, 2024

Your privacy is important to us. This statement discloses the privacy guidelines that serve as the basis for our user relationships with respect to users of all websites that display a link to this Privacy Policy and that are published by Johnson, Mirmiran & Thompson, Inc. (collectively, “JMT”). This policy does not apply to websites hosted by JMT on behalf of third parties, which are subject to their own privacy policies. JMT is committed to protecting your privacy. Please read the following to learn more about our Privacy Policy.

In this Privacy Policy (“Policy”), we describe our collection, use, disclosure and processing of personal information that we collect online via our websites (collectively, “websites”), as well as related to our products and services.

We use your personal data to provide and improve our services. By using our websites, you agree to the collection and use of information in accordance with this Privacy Policy.

Scope of this Policy

This privacy policy describes, generally, how JMT handles and processes personal information related to:

the use of our websites and associated services that link to this privacy policy (collectively, the “Website”)
job applicants and candidates who apply for employment with us through our Website
individuals who interact with our Website

Our collection, use and disclosure and processing of personal information about individuals will vary depending upon the circumstances. This Policy is intended to describe our privacy and data protection practices related to the interaction and use of our Website.

This Policy does not apply to the personal information we process relating to our employees and non-employee workers whose personal information is subject to different policies.

In this Policy, our use of the term “personal information” includes other similar terms under applicable privacy laws—such as “personal data” and “personally identifiable information.” In general, personal information includes any information that identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

When you interact with our Website, we may collect and process certain personally identifiable information. Personally identifiable information may include, but is not limited to:

Identifiers such as your name, the company you are associated with, your role with your company, your company address, your phone number and email address;
Your demographic information, including employment information if you are applying for employment;
Your geolocation data;
Internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement;
Information you may voluntarily submit to us;
Your participation in marketing and other events; and
Our communications with you, including whether you opened an email that we sent to you, clicked on any links contained in the email, and information about the device you used to do so.

Categories of sources of personal information: We may collect personal information directly from you, as well as automatically related to your use of our Website and other services, as well as from third parties. For example, we collect personal information:

from you, either directly (i.e., through information you submit to us, including via forms that you may complete and submit through our Website) or indirectly (i.e., by observing your actions on our Website).
from the content of surveys that you may complete
from ‘cookies’ and other similar tools or technologies deployed on parts of our Website
from our clients in connection with us providing professional services to them
from data analytics providers
from government entities
from service providers (i.e., companies who are assisting us in fulfilling our contracts and carrying out our business)
from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.

If you are a resident of a certain state, you may have the right to request that we disclose certain additional information to you about our collection and use of your personal information over the past 12 months. Please see Your State Privacy Rights below for more information.

Sensitive Information: Unless we specifically request or invite it, we ask that you not send or otherwise disclose to us your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. In those cases where we may request or invite you to provide the foregoing information, we will only do so with your express consent, in accordance with applicable data protection law requirements. Where you provide us with such information without request from JMT, we reserve the right (but do not have any obligation) to erase any such information at our discretion.

Usage Data

Usage Data is collected automatically when interacting with our Website.

Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access our Website by or through a mobile device, JMT may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Website or when you access our Website by or through a mobile device.

Tracking Technologies and Cookies

To optimize the user experience our Website may make use of Cookies and similar tracking technologies. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our services. The technologies We use may include:

Cookies or Browser Cookies. Cookies are small text files that a website transfers to your device to store and sometimes collect information about your usage of websites, such as time spent on websites, pages visited, language preferences, and other traffic data. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use the full extent of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our service may use cookies.
Web Beacons. Certain sections of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Google Analytics. JMT utilizes Google Analytics tracking services to collect anonymous user data to track visitor traffic, device and OS usage, and user trends. Google Analytics data is used by JMT and its affiliates to track marketing campaigns, identify potential site improvements, and view user trends. Google Privacy and Terms can be found here.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as you close your web browser.

Use of Your Personal Data

JMT may use Personal Data for the following purposes:

To provide and maintain our services, including to monitor the usage of our Website.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us.

To contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. By providing this information to us, you hereby consent to us contacting you using the information you provided.

To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

To manage your requests: To attend and manage your requests to us.

For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about you is among the assets transferred.

For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, services, marketing and your experience. Information submitted on an employment application will be used to process your employment application and evaluate your candidacy.

JMT may also display targeted advertisements based on personal information. Advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet the targeting criteria.

We may send you certain communications relating to JMT service, such as service announcements and administrative messages, that are considered part of your JMT account.

We may share your personal information in the following situations:

With Service Providers: We may share your personal information with third parties that perform services on our behalf such as running our sites, sending communications for us and executing marketing programs and promotions.
With Affiliates: We may share your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
With business partners: We may share your information with our business partners to offer you certain products, services or promotions. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. JMT uses reputable email service providers that implement high standards of care, protection and security of personal information.
Legal obligations: We also may share information about you, including personally identifying information, if sought by legal process or requested by law enforcement, or in order to protect the rights and property of JMT or the safety of our users or the public, or to protect against unauthorized use of our site.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

WE WILL NOT SHARE YOUR PERSONAL DATA WITH ANY NON-AFFILIATED THIRD-PARTY VENDOR OR WEBSITE OWNER FOR THEIR OWN MARKETING PURPOSES WITHOUT YOUR CONSENT.

Retention of Your Personal Data

JMT will retain Your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, or enforce our legal agreements and policies.

JMT will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our services, or we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your interaction with our websites represents your agreement to that transfer.

The Company will take reasonable steps designed to ensure that your data is treated securely and in accordance with this Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Security of Your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Children’s Privacy

JMT does not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information to JMT or use the Website, or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@jmt.com.

California residents under 16 years of age may have additional rights regarding the collection, sharing and sale of their personal information. Please see Your State Privacy Rights below for more information.

Links to Other Websites

Our Website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Additional Information for Residents of Certain Jurisdictions

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California

This section applies solely to visitors to and users of the Website who reside in the State of California. In addition, this section applies to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

We do not use or disclose your sensitive personal information other than to:

To perform the services or provide the goods reasonably expected by you when you request those goods or services or to evaluate or process your application for employment.
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information, provided that the use of your personal information is reasonably necessary and proportionate for this purpose.
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of your personal information is reasonably necessary and proportionate for this purpose.
To ensure the physical safety of natural persons, provided that the use of your personal information is reasonably necessary and proportionate for this purpose.
For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us, provided that your personal information is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
To perform services on behalf of the business, provided that the use of your personal information is reasonably necessary and proportionate for this purpose.
To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us, provided that the use of your personal information is reasonably necessary and proportionate for this purpose.
For purposes that do not infer characteristics about you.

The California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), provide California residents with the following rights:

The right of Californians to know what personal information is being collected about them;
The right of Californians to request the deletion of personal information collected from and retained about them (subject to certain exceptions);
The right of Californians to know whether their personal information is sold or disclosed and to whom;
The right of Californians to say no to the sale of personal information;
The right of Californians to access their personal information;
The right of Californians to rectify their personal information;

In addition, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

You have the right to request that we correct any inaccurate personal information we maintain about you.

You have the right to request that we stop all sharing of your personal information with third parties for purposes of cross-context behavioral advertising.

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Colorado, Connecticut, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia [1]

This section applies solely to visitors to and users of the website who reside in Colorado, Connecticut, Indiana, Iowa, Montana, New Jersey, Tennessee, Utah and Virginia and are acting in an individual or household context.

Colorado, Connecticut, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia each provide their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Data portability.
Opt-out of sales of personal information.

Colorado, Connecticut, Indiana, Montana, New Jersey, Oregon, Tennessee, Texas, and Virginia each provide their state residents with rights to:

Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
Opt-in to processing sensitive data.

Colorado, Connecticut, Indiana, Montana, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia each provide their state residents with rights to opt-out of processing for profiling/targeted advertising purposes.

Colorado, Connecticut, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, and Virginia each provide their state residents with rights to opt-out of automated decision making.

Exercising State-Specific Rights

To exercise any of the rights described above, please submit a verifiable consumer request to us through the methods below.

Email: Privacy@jmt.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

California residents may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Appealing Decisions on Data Requests

You have the right to appeal a refusal to take action on a request within a reasonable period of time after your receipt of our decision. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you will be provided with an online method through which you may contact the Attorney General of your state of residence to submit a complaint.

Changes to this Privacy Policy

We may update Our Policy from time to time. We will notify you of any changes by posting the new Policy on our Website and updating the Policy’s effective date.

You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Us

If you have any questions about this Policy, You can contact us:

By email: privacy@jmt.com

By visiting this page on our website: https://jmt.com/contact

[1] Indiana effective only as of January 1, 2026; Iowa effective only as of January 1, 2025; Montana effective only as of October 1, 2024; New Jersey effective only as of January 15, 2025; Oregon effective only as of July 1, 2024; Tennessee only effective as of July 1, 2025