Last modified: February 20, 2018 

PRIVACY POLICY

I. Introduction.

(A) CTRL SHFT, Inc. (“Company” or “We”), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (the “Privacy Policy”, as may be referred to in other Company documentation, including the Terms of Use). This policy describes the types of information we may collect from you or that you may provide when you (i) visit the JRNI application, the website www.jrni.co and all subdomains related thereto, or any social media pages (or forums), or JRNI Coaching Program (as further defined in the Terms of Use, the “Platform”), (ii) use our Services (defined in Terms of Use), and (iii) participate in the JRNI Coaching Program (as further described in the Terms of Use), and our practices for collecting, using, maintaining, protecting, and disclosing that information. 

(B) This policy applies to information we collect:

(i) on this Platform, including the Program Platform (defined in the Terms of Use); or 

(ii) in email, text, or other electronic messages (including support or tickets) between you and this Platform, JRNI Coaching Program, or Services, including but not limited to communications related to the Catalyst Course.

(C) It does not apply to information collected by us offline or through any other means, including on any other website operated by Company or any third party. 

(D) Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your remedy is to not access or use our Platform, JRNI Coaching Program, or the Services, or participate in the Platform or the JRNI Coaching Program. This policy may change from time to time. Your continued use of this Platform, JRNI Coaching Program, or our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

II. Persons Under the Age of 18. Neither our Platform nor our Services is intended for persons under 18 years of age. No one under age 18 may provide any personal information to or on the Application, Platform, JRNI Coaching Program, or our Services. We do not knowingly collect personal information from children under 18. If you are under 18, you may not use the Platform or register for our Services, make any purchases through the Platform or our Services, use any of the interactive features of this Platform or our Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any username you may use. If we learn we have collected or received personal information from a person under 18, we will delete that information. If you believe (a) we might have any information from or about a child (under the age of 18, for these purposes), or (b) a user’s activities are inappropriate, please email any additional supporting information you have to info@jrni.co. 

III. Information We Collect About You; How We Collect It. 

(A) We collect several types of information from and about users of our Platform and our Services, including information:

(i) Provided by you; to register as a user with our JRNI Coaching Program, you will be asked to sign in either with your own created username or password. In doing so, you authorize us to access certain information provided by you (“personal information”). Further, you may be asked to allow our Services to collect your location information from your device when you download or use our Services or the Platform, including identifying information, such as your name, address, email address and telephone number, and, if you transact business with us, some financial information. If you chat with our user support team using any of our Services, you provide us the content of written chat transcripts. We may share or disclose your non-private, aggregated or otherwise non-personal information with third parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services and for marketing purposes. You may opt out of receiving marketing messages by using the opt-out mechanisms and links provided in each email; 

(ii) that is about you but individually does not identify you; or 

(iii) about the equipment you use to access our Application, Platform, JRNI Coaching Program, or our Services, and usage details. 

(B) We collect this information: 

(i) directly from you when you provide it to us; 

(ii) automatically as you navigate through the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and 

(iii) automatically from your mobile device (including, without limitation, any mobile devices or tablets) when you use our Services, including your IP address, device ID and type, operating system, MAC address, browser type and language, the operating system, access times, geographic location while the application is actively running, and any referring Platform address; and 

(C) The information we collect on or through our Platform, JRNI Coaching Program, or our Services may include: 

(i) information that you provide by filling in forms on our Platform, JRNI Coaching Program, or our Services. This includes information provided at the time of registering for our Services (as defined in the Terms of Use). We may also ask you for information when you report a problem with our Services; 

(ii) records and copies of your correspondence (including email addresses), if you contact us; or 

(iii) your responses to surveys that we might ask you to complete for research purposes. 

As you navigate through and interact with our Services through the Platform, JRNI Coaching Program, or our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your visits to our Services and use of our Services, including traffic data, location data, and other communication data and the resources that you access and use for our Services. 

(D) The information we collect automatically is statistical data, but we may maintain it or associate it with personal information we collect in other ways. It helps us to improve our Platform and our Services, and to deliver a better and more personalized service, including by enabling us to: 

(i) estimate our audience size and usage patterns; 

(ii) store information about your preferences, allowing us to customize our Services according to your individual interests; 

(iii) speed up overall application infrastructure; or 

(iv) recognize you when you return to the Platform or use our Services.

(E) The technologies we use for this automatic data collection may include: 

(i) Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform. 

(ii) Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. 

IV. How We Use Your Information. 

(A) We use information that we collect about you or that you provide to us, including any personal information: 

(i) to present our Platform, our Services and its contents to you; 

(ii) to provide you with information, products, or services that you request from us; 

(iii) to fulfill any other purpose for which you provide it; 

(iv) to provide you with notices about your user account; 

(v) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; 

(vi) to perform research and analysis about your use of, or interest in, our products, services, or content; 

(vii) to communicate with you via email, telephone, postal mail, or mobile devices about products, venues, or services that may be of interest to you either from us or other third parties; 

(viii) to develop, display, and track content tailored to your interests on the Platform or our Services; 

(ix) to provide or analyze Platform, JRNI Coaching Program, or our Services analytics; 

(x) to verify your eligibility and deliver prizes in connection with any contests and sweepstakes; 

(xi) to notify you about changes to our Platform, our Services, or any products or services we offer or provide though it; 

(xii) on any other way we may describe when you provide the information; or 

(xiii) for any other purpose with your consent. 

(B) In all circumstances listed in (A) above, we may perform these functions directly or use a third-party vendor to perform these functions on our behalf who will be obligated to use your personal information only to perform services for us. Please note that this Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of our Services. 

(C) If you are a job applicant or service provider to the Company, and your personal information is submitted through the Platform, JRNI Coaching Program, or our Services when applying for a position or job with the Company, the information will be used solely to consider and act upon your application materials. We may retain your personal information, but only to consider your application for current or future available positions or jobs. This information, which may include your name and contact information, prior education and experience, and other information you provide to us, may be shared with third-party service providers retained by us to collect, maintain, and analyze candidate submissions for job postings. 

(D) If you contact our support team through the Platform or our Services, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints or reports that we receive from you about other users (and from other users about you). We will not provide you information about users who report you. 

V. Disclosure of Your Information. 

(A) We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Privacy Policy: 

(i) to our subsidiaries and affiliates; 

(ii) to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; 

(iii) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Services or Platform users is among the assets transferred; 

(iv) to fulfill the purpose for which you provide it; 

(v) for any other purpose disclosed by us when you provide the information; or 

(vi) with your consent. 

(B) We may also disclose your personal information: 

(i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; 

(ii) to enforce or apply our Terms of Use and other agreements; or 

(iii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our Services users, you, or others. 

VI. Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

(A) Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s Platform. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

(B) Do Not Track Disclosure. Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. DNT is a way for users to inform Platforms and services that they do not want certain information about their webpage visits collected over time and across Platforms or online services. However, because of the uncertainty of DNT in the internet industry, and the various factors and players conforming compliance, we may not recognize nor respond to DNT signals.

 VII. Accessing and Correcting Your Information.

You may review and correct your personal information through our Services. If you choose to close your account or terminate your relationship with the Services, we will retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Services or our users, or take other actions otherwise permitted by law. 

VIII. Deactivation; Termination of Your Account. 

(A) When your account is deactivated or terminated, for any or no reason as may be determined by the Terms of Use, we take reasonable efforts to make sure it is no longer viewable on our Services. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your account. 

(B) To prevent abuse of the Platform, JRNI Coaching Program, or our Services by a user following termination or deletion of an account, we shall retain such information as we deem in our sole discretion may be necessary to ensure that the user does not open a new account or profile in violation of our Terms of Use or other restrictions, and to ensure compliance with all laws and regulations. 

(C) After you remove information from your profile or delete your account, copies of that information may still be viewable or accessed to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. 

IX. Your California Privacy Rights. 

California Civil Code Section 1798.83 permits users of our Platform, JRNI Coaching Program, or our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@jrni.co. 

X. Data Security. 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where you have access to certain parts of our Services or the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform, JRNI Coaching Program, or our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform, JRNI Coaching Program, or our Services. 

XI. Communicating with You. 

We may provide you with emails, alerts and other messages related to the Platform, JRNI Coaching Program, or our Services, such as enhancements, offers, products, events and other promotions. With respect to other types of messaging or communications, such as emails, text messages, etc., you can unsubscribe or opt out by either following the specific instructions included in such communications, or by emailing us with your request at info@jrni.co. 

XII. Changes to Our Privacy Policy. 

It is our policy to post any changes we make to our Privacy Policy to this subdomain page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Platform, JRNI Coaching Program, or our Services. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting our Platform, JRNI Coaching Program, or our Services and this Privacy Policy to check for any changes. 

XIII. Contact Information.

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at info@jrni.co.