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Janrain respects your privacy and will treat the personal data you choose to share with us in accordance with our privacy policy.
 

Privacy Policy

Effective as of May 23, 2018.

TRUSTe

Janrain, Inc. is committed to respecting your privacy and protecting your personal information.

This Privacy Policy explains how we collect, use, and disclose your personal information, whether you are visiting our websites or using the Janrain Identity Cloud services we provide to our clients. We want you to have the information you need to make informed choices about the personal information we collect and process.

By visiting this website, you are accepting and consenting to the practices described in this policy. 

This Privacy Policy is intended to help you understand:

  1. Web Sites Covered, Data Controller, and DPO
  2. Personal Information We Collect
  3. Use of Personal Information Collected
  4. Sharing of Personal Information Collected
  5. Your Choices, Communication Preferences, and Rights
  6. Security
  7. Cross-Border Data Transfers and Privacy Shield Notice
  8. Our Role and Practices Related to Client Data
  9. Our Policy Towards Children
  10. Correcting and Updating your Personal Information
  11. Changes to this Privacy Policy
  12. Contact Information

1. Web Sites Covered, Data Controller, and DPO

This Privacy Policy covers the information practices of Janrain, Inc.  as it related to personal information collected through its websites that link to this Privacy Policy, including http://www.janrain.com; http://janrain.com/; http://trust.janrain.com/; https://rpxnow.com/privacy. These websites are hosted in the United States.  If you submit your personal information on the websites, it will be transferred to the United States.

With regard to personal information submitted to Janrain websites, the data controller is Janrain, Inc., 1233 NW 12th Ave., Suite 150, Portland, OR 97209, USA (“Janrain”). Janrain’s data protection officer is Lewis Barr, who may be contacted using the contact information below.

Our websites may contain links to non-Janrain websites. We are not responsible for the information practices or the content of such other websites. We invite you to review the privacy policies of those other websites to understand their information.

2. Personal Information We Collect and Process

  • Lawful Bases for Processing

We collect and process your personal information when we have lawful bases for doing so.  These lawful bases include when you provide us with consent, when we have a contractual obligation to collect or process your personal information, and when we have a legitimate interest in processing your personal information.

For example, in our capacity as a data controller we may process your personal data to:

  • Protect you, us, or others from threats (such as security threats or fraud)
  • Comply with laws that apply to us
  • Enable or administer our business, such as for providing technical support and customer service
  • Understand and improve our business or customer relationships generally
  • Offer information regarding our company and services to you

If we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and if we rely on legitimate interests, you have the right to object.

  • Information You Give Us

We receive and store any information you enter on our Website or give us in any other way. This information may include (a) your name, email address, job title, and other personal information; (b) your interaction with website features; (c) transaction-related information, such as, when you download software from us; and (d) information you provide us when you contact us for assistance. You also should know that any information you provide to our Website blogs may be read, collected, and used by others who access them. 

  • Information We Collect Automatically and Cookies

Janrain and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

  • Behavioral Targeting

We partner with third parties to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish not to have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

  • Do-Not-Track

There are different ways you can prevent your online activity being tracked. One of those is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain information about you. This is referred to as a Do-Not-Track (“DNT”) signal. Please note that our websites may not recognize or take action in response to DNT signals from web browsers. At this time, there is no universally-accepted standard for what a company should do when a DNT signal is detected. In the event a final standard is established, we will assess how to appropriately respond to these signals.

For more detailed information about cookies, Do-Not-Track and other tracking technologies, please visit allaboutcookies.org and allaboutdnt.com.

  • Other Information Collected

You can log in to our Site using social identity providers such as Facebook, Google +, or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.

Our site also includes social media features, such as the Facebook Like button and widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

  • Prospective User Data Supplementation

We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us update, expand and analyze our records, identify new clients, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Examples of the types of personal information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include purchased marketing data about prospective clients from third parties that is combined with information we already have about you, to create more tailored marketing advertising and products.

3. How We Use Personal Information We Collect

We may use your information (a) to deliver our website services and features desired by you (including any customization features requested by you), (b) to improve our services for you, (c) to personalize content and offers that may be of interest to you in pursuit of our legitimate interests to expand our business, (d) to respond to your inquiries, and (e) to fulfill your request for products or services. If provided, we may use your email address to contact you from time to time.

4. Sharing of Personal Information Collected

We share information that identifies you only as described below and with subsidiaries we control that follow the same practices described in this Privacy Policy. We do not sell your personal information to third parties.

.    Third Party Service Providers: We may retain other companies and individuals to perform functions on our behalf, such as sending email, removing repetitive and inaccurate information from customer lists, analyzing data, processing credit cards, and providing marketing assistance. These companies are authorized to use your personal information only as necessary to provide these services to us.

.    Some of our pages utilize framing techniques to serve content to and from our partners while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to Janrain.

.    Protecting Others and Ourselves: We will disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and if we believe disclosure is necessary to protect our rights, property, or safety, our customer, or others. In particular, we may cooperate with law enforcement agencies in any official investigation and disclose your personal information to the relevant agency in doing so.

.    Business Transfer: We reserve the right to transfer your personal information in the event Janrain, Inc. or substantially all of our assets are acquired. You will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

.    With Your Consent: Other than as stated above, we will not disclose or provide your personal information to a third party without your explicit consent for us to do so. For example, we often display personal testimonials of satisfied Clients on our public websites. With your consent, we may post your name alongside the testimonial.

5. Your Choices and Rights and How to Exercise Them

Choices

  • As a visitor to our website you can always choose not to provide us with personal information when requested, although it may be required for you to take full advantage of our website offerings.
  • If your browser is not already set up to refuse cookies, you can configure your browser to refuse them. By doing so you may not be able to take full advantage of our website features.
  • You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails. Additionally, you may specify your communications preferences at http://www1.janrain.com/UnsubscribePage.html.

If you purchase a service from our website and create an account, you may later access, update, or delete your information on the service dashboard or by contacting us at privacy@janrain.com. To update Billing Information you can contact our Finance department or submit a ticket to support via the support portal. We will respond to your access request within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You may also request deletion your personal information by contacting us at privacy@janrain.com. Clients, however, cannot opt out of receiving transactional emails related to their account.

Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information.  To request this information please contact us by writing to Data Protection Officer, Janrain, Inc., 1233 NW 12th Ave, Suite 150, Portland OR 97209 USA and provide your name, address, and email address, so that we have sufficient detail to respond to your inquiry. If you have established a Janrain account or submitted information to us on our website, you may submit your inquiry to privacy@janrain.com. If you do, please provide your name, address, and email address and, if applicable, account information.

Rights

If you are resident in the European Economic Area, under European law you have the following rights in respect of your personal information that we hold in our capacity as the operator of our websites or the data controller:

  • Right of access. You have the right to obtain:
    • confirmation of whether, and where, we are processing your personal information;
    • information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
    • information about the categories of recipients with whom we may share your personal information; and
    • a copy of the personal information we hold about you.
       
  • Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
     
  • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
     
  • Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
     
  • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
     
  • Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you, if that is the case. You can object to marketing activities for any reason.

To exercise one of these rights with respect to information we have collected from you on our websites or otherwise as a data processor, please contact us using the contact information provided below.

You also have the right to submit a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Residents of countries in the European Economic Area may have additional rights under their laws and residents in other jurisdictions may have rights similar to those listed above.

You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws. To be clear, if you contact us to exercise a right with respect to information we are processing on behalf of a Client we will refer your request to the Client and let you know of such referral.

If you have unresolved concerns, you have the right to report them to an EU or other data protection authority where you live, work or where you believe a potential violation may have occurred.

6. Security

Janrain uses appropriate technical, operational, and administrative safeguards to help protect the security, confidentiality, and integrity of the personal information and other data submitted to Janrain. We cannot guarantee, however, that data may not be accessed, disclosed, altered, or destroyed by a breach of our safeguards. The security of your personal information also depends on your protection of your account. Please do not disclose your website login credentials to unauthorized people. Also, be sure to sign off when finished using a shared computer.

7. Cross-Border Data Transfers and Privacy Shield Notice

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. These mechanisms include the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and European Commission-approved standard contractual data protection clauses to safeguard the transfer. 

Privacy Shield Notice

Janrain participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Janrain is committed to subjecting all personal data received from European Economic Area (EEA) and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List: https://www.privacyshield.gov/list.

Janrain is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Janrain complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Janrain is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

In certain situations, Janrain may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

8. Our Role and Practices Related to Client Data

As a provider of Janrain Identity Cloud services, we may receive and host on our Clients’ behalf such personal information and other data which our Clients may provide to us for hosting (collectively, “Client Data”). Our Clients are the data controllers of Client Data and we are the data processor for each of our Clients with respect to Client Data. In processing personal information on behalf of our Clients, we follow their instructions with respect to the information they control. In doing so, we implement appropriate technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, personal information. We do not determine how our Clients use Client Data, and we will not access or disclose it except as directed or agreed to by our Clients or required by law.

Janrain acknowledges that you have the right to access your personal information. Janrain collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. Janrain will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Notice and Choice: Individuals may submit personal information to our Clients through the use of the website registration and login services we provide to our Clients. (Some of these services may have a notice that they are “powered by Janrain”). This personal information is submitted with notice to, and the consent of, the individual user via identity providers’ permission screens, or voluntarily provided by the user at registration. Once Janrain has successfully facilitated the transmission of personal information to a Client’s database that is not hosted by Janrain, it is that Clients’s responsibility to guard the personal information against unauthorized access or transmission.

Accessing, Correcting, Amending, or Deleting Personal Information: If you are an individual seeking access to, or who would like to correct, amend, or delete your personal information which Janrain may be storing on behalf of our Client, you should direct your request to the applicable Janrain Client acting as the data controller for such information. Clients may access, and delete Client Data, including an individual record, via an application provider interface or API. If requested to remove/access data we will respond within 30 days. Following the deletion of personal information in a database we host, the related backup data will be deleted, generally within 10 days.  Janrain will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Cookies Related to Our Social Login Service

The following table shows how cookies are placed on user browsers in connection with our Social Login service. Each is required to deliver critical functionality or complete the users’ service requests.

TypeCookie NameCreatedStored DataUsage
Sessionlogin_tabWhen the user clicks on a social sign-in linkIdentity provider name or identifierRecords which identity provider has been selected by the user, for use during the transaction
Sessionexpected_tabAfter a successful social sign-in transactionIdentity provider name or identifierRecords which identity provider has successfully authenticated the user, for use during the transaction
Permanentwelcome_info_nameAfter a successful social sign-in transactionDisplay name of user as returned by identity providerRetrieves a display name for providing visual confirmation to end user

An individual using our Single Sign On service will have three cookies placed on his or her browser: session_id; visited; and janrain_sso_checked <domainspecifier>. These cookies are required to enable the service.

Statistics

To assist our Clients and partners, and to market our services, we may disclose aggregated, statistical information related to the use of our services by some or all of our Clients and their users. Such information will not contain any personal information or identify any customer or user of our services.

9. Our Policy Towards Children

Our Services are not directed at persons under 16, children are not eligible to use our websites and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, please contact us using the details below so that we can take steps to delete your child’s information and terminate any account your child has created with us.

10. Correcting and Updating Your Personal Information

You can request the removal of your personal information from our blog or community forum, by contacting us at privacy@janrain.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

11. Changes to this Privacy Policy

From time to time we may update this Privacy Policy. If we do, we will update the “effective date” at the top of the Privacy Policy. If we make an update with changes that are materially less restrictive regarding our use and disclosure of your information, we will provide prior notice of such changes by posting notice on our website at the top of the then current Privacy Policy 30 days before the effective date of the update. You should visit this page periodically to review any such changes to the Privacy Policy. Your continued use of this website or our service and/or continued provision of information to us will be subject to the terms of the then-current Privacy Policy.

12. Contacting Us

Questions regarding this Privacy Policy or about information practices of Janrain websites should be directed by email to privacy@janrain.com or by mailing Janrain, Inc.
Attn: Data Protection Officer, 1233 NW 12th Ave, Suite 150, Portland OR 97209.