JOFI®, LLC Privacy-Cookie Policy
We are JOFI. Formally, we are Jofi, LLC (“JOFI®”, “JOFI”, “we”, “us”, and “our”). Among other things, we provide a streamlined and privacy-focused process to provide job seekers with links to potential employers’ websites. As part of this effort, we provide our services online, including via the JOFI app (the “JOFI App”) and the websites at https://jofi.work and https://jofiwork.com (each, the “JOFI Site”) (collectively, the “Services”).
Important Notice: JOFI currently provides Services to United States residents in the states of Florida, Georgia, Maryland, New Jersey, Pennsylvania, Virginia, and in Washington, D.C. Our services are not intended to be used outside of these locations. If you reside outside of these locations, you are not authorized to use our services and please do not use our Services or terminate your use of our Services.
Each person or entity who uses our Services is referred to as a “user” or “you” or “your”. This Privacy-Cookie Policy (“Policy”) and our Terms of Service (“Terms”) apply to each user.
This policy is our statement of our privacy and cookie practices. Among other things, it explains how we and some of the companies, entities, and organizations we work with collect, use, share and protect the information you provide to us (your “Content” or “User Content”). The User Content may include any personally-identifiable information that you provide to us through the Contact Us form or via email or by mail, including without limitation name, address, telephone numbers, electronic mail and postal addresses, and other sensitive information that identifies or is uniquely associated with an individual (collectively, “Personal Data”). This Policy also discusses our handling and/or your choices, if applicable, about the collection, storage and use of your Personal Data.
Any Content that is not Personal Data is referred to as “Non-Personal Data.” Non-Personal Data may include without limitation information about how users use the Services, what Services users select, how users respond to service offerings, how users share information with others, what users say they like and dislike, all of which may be aggregated into larger data sets that do not identify individuals (collectively, “Behavioral Data” which is a type of Non-Personal Data).
Among other services, JOFI may post links to third-party websites including prospective Employers’ websites. Please note that this Policy applies only to JOFI Site and JOFI App and does not apply to any other websites, mobile applications, or businesses. Although this Policy focuses on Content that you provide to us through the Contact Us form or via email or by mail or we collect via our Services, it also applies to any Personal Data and other Content we may collect or process via any means, including via our Services
By using our Services, you consent to the collection, transfer, analysis, transformation, storage, disclosure and other uses of your Content, including your Personal Data, as described in this Policy.
For the purpose of any privacy laws which use the terms “controller” and “processor” with regard to Personal Data, JOFI is the “Data Controller” meaning that JOFI is the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. Our service providers and contractors who process Personal Data are each the “Data Processor”, meaning that they process Personal Data at our direction.
Information We Collect
As noted above, we collect Content from you while providing the Services. Some of the Content is Personal Data that you provided to us through the Contact Us form or via email or by mail which we may use to contact you as a reply to your inquires and/or necessary to provide the Services. Other Content we may collect from you includes Non-Personal Data that we aggregate, share, and use to improve our Services, and the services of others. We do not collect or store user data, users’ device ID numbers or IP addresses. We do not track or retain users’ device location and related data, or analyze user preferences and behavior. We also do not collect or store personally sensitive user data including financial and payment information. We do not share, sell, rent, or lease personal identifiable information. We want users to visit the JOFI Site and use the JOFI App without fear of being tracked digitally.
We collect different types of information from you, both directly and indirectly:
Information you provide us directly
We may collect the following information from you.
Communication between you and JOFI: We may send you emails as a reply to your inquires submitted through the Contact Us form or via email to us. We may collect and store these communications.
Information we gather from your use of our Services
We collect the following information from your use of our Services.
Emails. We may save emails sent to us by users, and we may share your emails with any third parties or other users.
Analytics. We do not use or affiliate with third-party analytics tools, such as Google Analytics, to measure traffic and usage trends and other Non-Personal Data (as that term is defined above in our Privacy-Cookie Policy) for the Services.
Metadata. Metadata is usually technical data that is associated with other data, including User Content. For example, metadata can describe how, when and by whom an item of User Content was collected and how that User Content is formatted. JOFI may collect and store metadata, including about each user’s communication with the Services.
Log Data. Our servers automatically record information (“log data”) created by your use of the Services. Log Data may include information such as your Internet Protocol (“IP”) address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive log data when you interact with our Services, for example, when you visit the JOFI Site or use the JOFI App, or interact with us through the Contact Us form or via email. JOFI may use log data to review how we provide our Services and to measure, customize, and improve the Services.
How We Store Your Information
We currently provide the Services from within the United States, and we store all User Content, including Personal Data, that we currently collect and retain on servers inside the United States.
Certain types of User Content you submit to us through the Contact Us form or via email or by mail might reveal your gender, ethnic origin, nationality, age, religion, sexual orientation, or other Personal Data about you or others.
By using our Services, or by submitting your personal information to us, you consent to the collection, storage, processing, and onward transfer of your personal information as stated in the current version of this Policy and the current version of our other online documents, including the Terms of Service.
Advertising
We do not share, sell, rent, or lease users’ personally identifiable information and information provided by or collected from users searching for jobs or communicating with us through the Contact Us form or via email or by mail (such as your name and email address). Any changes to our current policy of not sharing, selling, renting, or leasing users’ information will be clearly disclosed in an updated version of this Policy.
How We Use Your Information
We may share and use your Personal Data in the following circumstances. Unless specifically state below, these do not include the use of Biometric Information:
To provide and maintain the Services, including to monitor the usage of our Services.
Partners and Affiliates of JOFI. We may share your Personal Data with Partners and/or Affiliates to provide and maintain the Services.
Cookies. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device and to provide features and remember your personalization choices. We use cookies to make it easier to access and use our Services. The help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the website of its manufacturer. Because cookies allow you to take advantage of some of the Services’ essential features, we recommend that you leave them turned on. Cookies are also used to display particular Content and to set session identifiers for visitors who voluntarily join user areas. We may use and rely on strictly necessary cookies and other related technology only to create a unique identifier for the JOFI App’s installation on the specific device for debugging purpose if such problems exist.
Do not Track. We honor general opt-out preference signals such as Global Privacy Control; however, the specific “Do Not Track” setting has been found to enable the fingerprinting of user devices, and companies have generally moved away from this standard. Therefore, we do not honor the “Do Not Track” setting on users’ devices.
Required by Law. We may access, preserve, and share your Personal Data in response to a legal request (like a search warrant, court order or subpoena). We may also access, preserve, and share Personal Data when we have a good faith belief that it is necessary to: help to ensure security and integrity generally to the extent that your Personal Data is reasonably necessary and proportionate for those purposes; detect, prevent, and address fraud and other illegal activity; to protect ourselves, you, and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm
Change of Control. If we sell or otherwise transfer part or the whole of JOFI or our assets to another organization (e.g., a merger, acquisition, or reorganization), your Personal Data such as email address, User Content and any other information that you provided to us through the Contact Us form or via email or by mail, and any other information or data collected through the Services may be among the items sold or transferred. You will continue to own your User Content, but the license you grant to us in the Terms may be transferred to others at JOFI’s sole discretion
Non-Personal Data. We may share Non-Personal Data publicly and with affiliates, advertisers, publishers, researchers or connected sites. For example, we may share aggregated Non-Personal Data publicly to show trends about the general use of our Services. Non-Personal Data includes aggregated or collective information about multiple users that does not reflect or reference an individually-identifiable user.
Others. In addition to some of the specific uses of information we describe in this Policy above, we may use Personal Data that we receive to:
provide, improve, test, and monitor the effectiveness of our Services
develop and test new products and features.
Monitor metrics such as total number of visitors, traffic, and demographic patterns.
diagnose or fix technology problems.
Your Right to Review, Request Changes, and Disclose Personal Data
Where required by applicable laws and regulations, each user may inspect and receive a copy of his or her Personal Data, which was provided to us by the user through the Contact Us form or via email or by mail, as stored in the Services. In rare circumstances, we may deny a request, and we may provide you with an explanation. If we deny your request, you may request a review by another professional, who will be chosen by JOFI, and we will comply with the outcome of the review.
Subject to applicable laws and regulations, the Personal Data you provide to us through the Contact Us form or via email or by mail remains completely under your control. If you believe the Personal Data we have is incorrect or incomplete, you may in writing request an amendment to your Personal Data. We will approve or deny each request, and notify you of our decision. If approved, we will amend the Personal Data. We will also make a reasonable effort to notify people to whom the Personal Data was released. In the case of a denial, we will provide the reason for the denial and instructions on how to appeal.
Any Information or User Content that you voluntarily disclose to us through the Contact Us form or via email or by mail, such as your name, your email address, your Personal Data or other User Content or information, may become available to the public if you release it to other users or to the general public. Once you have shared your Personal Data and your User Content with other people, or otherwise made it public, that Personal Data and your User Content may be re-shared by others.
Changes to this Privacy-Cookie Policy
We may modify our Policy from time to time without prior written notice. If you choose not to be subject to a revised version of the Policy, then do not continue your use of our Services.
Different Locations, Different Laws
The laws and regulations that address privacy rights and responsibilities (collectively, “Laws”) are different from one to another. Indeed, some of the Laws do or do not apply depending on different factors, including:
Location or residence of the user.
Location or residence of the individual that is the subject of the Personal Data (“Data Subject”).
Location or residence of the person or organization that employs or contracts with the Data Subject.
Location of each server or other machine where the Personal Data is received, stored, processed, or forwarded to.
Location of the relevant office of JOFI or any company that processes Personal Data.
Several of the Laws that concern users and JOFI are discussed in this Section, but additional laws may apply. In addition, if there is any conflict or ambiguity between the statements made in this Policy and an applicable Law, then the applicable Law will control.
7.1 Consent to United States Law
All Personal Data and other data provided by users will be stored in the United States under United States law. Accordingly, United States law will apply to all users. All users consent to the application of the law of the United States in connection with the Services.
7.2 United States Federal and State Laws
Several of the federal Laws in the United States may apply to the Personal Data collected by us. Congress has passed several federal information privacy and security laws, while each state in the United States has passed and enforces information privacy and security laws that apply to data subjects, data, and businesses resident in that state.
Currently, all Personal Data of JOFI users is stored on servers and other machines physically located within the United States. From time to time, Personal Data may be moved between servers in the same location or may be moved to a different location. When we receive a verified request by a user, we will provide the user with information required by applicable laws regarding the location and storage of their Personal Data.
7.2.1 Children’s Online Privacy Protection Action (“COPPA”)
Currently, COPPA should not apply to the Services. As stated in the Terms of Service, JOFI is not meant to be used by anyone under 18 years old. IF YOU ARE LESS THAN 18 YEARS OLD, YOU MAY NOT USE ANY OF THE JOFI SERVICES AND MAY NOT SUBMIT, TRANSMIT, OR COMMUNICATE ANY INFORMATION, DATA, COMMENTS OR PHOTOGRAPHS TO US. EACH USER MUST BE 18 YEARS OF AGE OR OLDER. As noted in this Privacy-Cookie Policy, if we learn any user is under the age of 18 (“Minor User”), or if any parent or guardian contacts us, we will delete all information provided by the individual from our Services. Moreover, users of the Services are responsible and liable for compliance under COPPA and are prohibited from collecting, using, and/or disclosing personal information from and about children in connection with the use of the Services, or assisting any third party in doing so.
If you are the parent or guardian of a Minor User, and you become aware that your Minor User has provided us with Personal Data or User Content, please contact us at info@jofi.work and we will delete the information or User Content.
7.2.2 Your Privacy Rights Under State Laws
Important Notice: JOFI currently provides Services to United States residents in the states of Florida, Georgia, Maryland, New Jersey, Pennsylvania, Virginia and in Washington, D.C. Our services are not intended to be used outside of these locations. If you reside outside of these locations, you are not authorized to use our services and please do not use our Services or terminate your use of our Services.
This section supplements the information contained elsewhere in our Privacy-Cookie Policy and applies to all visitors, users, and others (“consumers” or you”). This notice of privacy rights has been adopted in order to comply with United States federal law and the laws of Florida, Georgia, Maryland, New Jersey, Pennsylvania, Virginia, and Washington, D.C., and any terms defined in such laws have the same meaning when used in this notice.
7.2.3 Specific Rights Under State Laws (see 7.2.2 above)
Under several state privacy and data protection laws (for example, California, Colorado, Connecticut, Utah, and Virginia), residents of those states may have one or more of the following rights and may exercise these rights free of charge. Since these state laws are generally modeled on the General Data Protection Regulation (GDPR) of the European Union, the following list mirrors the GDPR section below:
Right to lawfulness, fairness, and transparency: Requires that we follow these principles when processing your personal information
Right to Access: Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
Right to Rectification: Require us to correct any mistakes in your information which we hold
Right to Be Forgotten: Require the erasure of personal information concerning you in certain situations
Right to Data Portability: Receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to a third party in certain situations
Right to Object to Direct Marketing: Object at any time to processing of personal information concerning you for direct marketing
Right to Object to Automated Individual Decision Making: Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
Right to Restriction of Processing:
Object in certain other situations to our continued processing of your personal information
Otherwise restrict our processing of your personal information in certain circumstances
Use of Email Addresses and Other Contact Information
We may collect the email addresses or other contact information of users who voluntarily provide them to us through the Contact Us form or via email or by mail. You may receive email or letter from us replying to your inquires. If you do not want to receive email or letter from us in the future, please let us know at info@jofi.work.
How to Exercise Your Rights
If you would like to exercise any of your rights as described in this Privacy-Cookie Policy, please:
Complete a data subject request form available on our website;
Email us at info@jofi.work; or
Contact use by mail at “Attn.: Privacy, Jofi, LLC, 1101 Market Street, Suite 2820, Philadelphia, PA 19107
Verifying Your Identity
If you choose to contact us directly regarding your rights as described in our Privacy-Cookie Policy, you will need to provide us with:
Enough information to identify you (e.g., your full name and address)
Proof of your identity and address (e.g., a copy of your driver license or passport and a recent utility or credit card bill); and
A description of what specific right(s) you want to exercise and the specific information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
Contact Us
If you have questions or concerns about this Privacy-Cookie Policy, please contact us online at info@jofi.work, or by postal mail addressed to:
Attn: Privacy, Jofi, LLC, 1101 Market Street, Suite 2820, Philadelphia, PA 19107.
Revision Date and History
This Privacy-Cookie Policy was last revised: 3-18-2023
Prior versions of this Privacy-Cookie Policy are listed below:
6-25-2021