Privacy and Terms of Use Policy

This Privacy Policy shall apply to all information John Galt Staffing, Inc. and its affiliates, clients and partners receive from you via www.j-galt.com and any domains and affiliated websites and social media pages and applications, all of which we refer to in this Privacy Policy collectively as the “Site”, and information obtained about you as a result of your use of the Site.

California residents should refer to the important Notice at the end of this Policy for additional information.

This Privacy Policy also applies to (1) information you provide, whether electronically or though non-electronic communications like telephone calls and in-person meetings, in connection with our search, recruitment, placement and staffing services (collectively with any other services we provide, the “Services’), and (2) any information we collect about you from third parties in connection with your use of our Services.

We use the terms “we”, “us”, “John Galt” or the “Company” in this Privacy Policy to refer to John Galt Staffing, Inc. and its affiliates John Galt Professionals, Inc. and John Galt Operations, Inc., all of which are Massachusetts corporations.

Please read this Privacy Policy carefully.

By using the Site or otherwise submitting information in any format, you agree to be bound by this Privacy Policy.

Respecting Your Privacy

John Galt values its relationship with you and respects your privacy. We have provided this Privacy Policy in order for you to know how we gather, use and disclose information you provide while visiting the Site, interacting with us and our clients and partners, or utilizing our Services or those of our clients, partners or affiliates. This includes in particular the information candidates provide during the application and recruitment process for temporary assignments and permanent employment with John Galt clients.

This Privacy Policy also describes what other information may be collected, and how and under what circumstances such information is used and disclosed. If you use the Site and provide information via the Site or otherwise, then you do so in full agreement with the terms and conditions described in this Privacy Policy.

Information Gathering

We collect, store and use information, including personal data, to provide our recruiting, placement, staffing, and consulting services. The type of personal information collected depends on the Service being requested or provided.

1. User Submitted Data is information you personally elect to provide that identifies you as an individual or relates to you as an identifiable individual, whether you provide it by means of typing the information into a form, providing it in an email, submitting a job application or résumé, speaking with our employees on the phone, during your relationship with us and our clients, or otherwise.
2. Third Party Data is information we may obtain about you from third party sources, such as background check companies, prior employers, and government agencies.
3. Browser Derived Data is information we collect from your use of the Site – for example, the fact that you are accessing the Site using a smartphone.

Our collection and use of these types of information is covered by this Privacy Policy as described below.

User Submitted Data

User Submitted Data is information you provide that identifies you as an individual, such as:

• Identifiers and contact information: your name, mailing address, email address, and home and/or wireless telephone numbers.
• Educational information: schools attended, grades/transcripts, and degrees.
• Professional or employment-related information: employment history, professional credentials and skills, CV/résumé, and references.
• Other personal information required for us to provide Services: for example, citizenship information/work authorization, existing non-competes or other restrictions on employment and actual or possible conflicts of interest, criminal history and credit history (only to the extent permitted by, and in accordance with, applicable law), role-specific information such as whether you are proficient in skills required to perform the job, job search information such as whether you are seeking permanent or temporary employment, full or part-time, etc., and interview information such as availability for interviews and feedback from completed interviews.

User Submitted Data is typically collected from you when you visit the Site and submit a résumé or request contact or information about an employment opportunity. It also includes information you provide to our employees and agents by phone, a mobile application, email or any other means.

We also collect information about you from our clients with whom you may interact such as during an interview, from third parties like background check companies, and from public sources like government agencies. See below for a discussion about Third Party Data.

We may also use photos of you that you provide or make publicly available, such as via LinkedIn, and collect compensation and benefits information as permitted by law.

In certain cases, we may collect sensitive personal information such as your social security number, but will only do so directly and never via the Site. We may also request personal information for diversity, equity or other purposes, and to ensure our Services comply with applicable equal employment opportunity statutory and/or contractual requirements, on our own initiative or at our clients’ request. You are not required to provide such information.

We do not collect certain types of sensitive personal information, such as medical history, religion, biometric or genetic data, and political affiliation during the recruitment process. If you have a disability and would like an accommodation, you may provide that information during the recruiting process.

If you provide information to us about others, you represent that you have the authority to do so and permit us to use the information provided for the purpose for which it is provided and otherwise in accordance with this Privacy Policy.

Your provision to us of User Submitted Data is voluntary and can be limited or stopped at any time. If you elect not to provide certain information, you may not be able to participate in our Services, including employment opportunities.

We may use User Submitted Data for several purposes, including without limitation to:

• send you information about the Company and its Services, including details regarding specific current employment opportunities, prospective roles, and the status of your application,
• respond to your inquiries and questions, whether about the Company or any of our Services, including available jobs and Company clients,
• create a profile about you to reference for current and future employment opportunities,
• verify the information you provide to us to ensure its accuracy, including employment experience, professional skills/qualifications, education and references, and confirm that you are legally entitled to work,
• set up interviews and assessments,
• arrange assignments, including the completion and delivery of onboarding documents such as employment agreements and benefits enrollment documents (if any),
• manage training, development, performance and discipline issues,
• contact you or your family in case of emergency, and
• otherwise fulfill our contractual arrangements with you and our clients.

We may also use User Submitted Data to:

• send you information regarding the Company, the Site, changes to our terms, conditions, and policies, and other administrative information,
• personalize your experience on the Site and with John Galt, and with our clients, partners and affiliates, and
• assist with our business purposes, such as improving the Site, improving our Services and developing new ones, gauging candidate and employee satisfaction, meeting our legal obligations (including with respect to diversity and equal employment opportunities), and detecting and preventing fraud.

User Submitted Data also may be used by us to conduct analytics, as well as for research, development, sales, and marketing purposes, including the preparation of studies and papers. Any published product will refer only to aggregate, and not individual, data and will not identify any individual personally.

When you have given your consent to a relevant activity, such as a background check, you always have the right to withdraw such consent. Keep in mind that doing so may adversely affect our ability to place you in a particular assignment that requires such activity as a condition of the assignment.

[User Submitted Data you provide through the Site and to our affiliates, clients and partners may be combined with other information you provide (via online or offline means), with demographic information and other information that is publicly available, or with other information about you that we may otherwise obtain online or offline.]

We may disclose User Submitted Data to:

• our employees, agents, contractors and affiliates in connection with the provision of Services to you and our clients,
• our clients, and their agents and affiliates, that play a role in a transaction with you, including filling an open assignment or permanent position, and which includes the results of activities such as background checks and drug screens,
• third party service providers that provide support services for us in connection with our Services, such as background checks, education verification, reference and employment checks, employment eligibility confirmation, drug testing and screening, and security clearance/access, in each case to enable them to provide such services,
• other third party service providers that provide services for us such as attorneys and accountants, and third parties who provide website hosting, data analysis, data security, email delivery and other similar services, in each case to enable them to provide such services, and
• identify you to anyone to whom you send messages through the Site or otherwise.

Our employees, contractors, agents, affiliates and clients have access to your User Submitted Data on a need-to-know basis for the purpose of performing Services on our behalf. Those who are granted access have agreed to keep such information confidential and abide by the terms of this Privacy Policy, and not to use any such information other than to provide the goods and carry out the services they are performing on our, our client’s and/or your behalf, or as otherwise required by law.

The parties with whom we share your User Submitted Data, including our clients, may in turn share that information with others with a legitimate business need to know. They may contact you directly at the phone number(s) or email address(es) you provide to collect additional information, answer questions, complete transactions or provide you with information about other products and services (even if, in the case of phone calls, you have registered the phone In addition, we may partner with third parties to collect information on the Site to engage in analysis, research and development. These third parties may set and access cookies and other technologies, as described more in this Privacy Policy. We assume no responsibility or liability for the policies or practices of any such third parties. We strongly urge users to review the laws and practices of the third parties with which we conduct business.

We will not rent, sell or license any User Submitted Data constituting personal information or potentially personally-identifying information to any third parties.

Third Party Data

Third Party Data is information that is not submitted directly by you but that is instead provided by third party service providers to us or our clients in connection with our fulfillment of a transaction with you, including placement in a temporary employment assignment or permanent role.

All applicants for temporary assignments/permanent roles are subject to pre-employment screening. The types of screening performed will depend on the role. The objectives of such screening are to verify employment, education, and work authorization, among others. In most cases we use third party vendors to conduct such screening for us.

These third party service providers may access public and private databases and social media platforms. Your consent will be obtained when required, and may be withdrawn at any time, though note that withdrawal of consent may impact our ability and the ability of our clients to fully assess an applicant’s candidacy or otherwise provide a Service. When providing such consent, you permit us to use and disclose the information collected in accordance with this Privacy Policy.

Examples of Third Party Data include information obtained from:

• our vendors who perform background, criminal history and credit checks (to the extent relevant and in compliance with law),
• references that provide us confirmation of your educational and employment history, and
• government agencies that confirm items such as authorization to work.

We may use Third Party Data for several purposes, including to:

• assist with the fulfillment of a transaction you requested, including placement in a particular job opportunity,
• respond to your questions,
• provide you with updates and announcements concerning our Services, including newly available assignments and positions,
• personalize your experience on the Site, including by presenting job opportunities tailored to you, and
• assist with our business purposes, such as improving our Services and developing new ones and gauging candidate and client satisfaction.

In addition, we may partner with third parties to collect information on the Site to engage in analysis, research and development. These third parties may set and access cookies and other technologies, as described more in this Privacy Policy. We assume no responsibility or liability for the policies or practices of any such third parties. We strongly urge users to review the laws and practices of the third parties with which we conduct business.

We may combine Third Party Data with User Submitted Data (such as combining your name with your application history). The combined information will be treated by us as User Submitted Data.

Browser Derived Data

Browser Derived Data is information that is not submitted by you but rather is provided by or results from your access and use of the Internet and an Internet browser to connect to the Site. (Note that in the State of California, Browser Derived Data may be considered personal information under data protection laws.) Browser Derived Data includes browser specific information such as browser type, IP address, Internet Service Provider or “ISP” information, server log file information, referring/exit pages, date/time stamps, information collected through cookies, pixel tags and other technologies, and location information.

We receive Browser Derived Data by your access to the Site, including in the following manner:

• Certain information is collected by most Internet browsers, such as type of computer or other device, model, manufacturer, operating system, browser software details, and network connection type.
• Your “IP address” is a number that is automatically assigned to the computer or device that you are using by your ISP. An IP address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. We use IP addresses for purposes such as calculating usage levels of and engagement with the Site, helping diagnose server problems, and administering the Site.
• Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. We and our partners use cookies, analytics, remarketing and other similar tracking technologies as described in this Privacy Policy. A cookie enables the Site to label you as a particular user, but it does not identify you by name or address unless you have provided such information or set up preferences in your browser to do so automatically. If you do not want information collected through the use of cookies, your Internet browser has a tool to disable cookies and you may block their use when you visit the Site.
• We may use applications, including mobile applications or widgets, to collect information from you.
• The Site may also use pixel tags, web beacons, clear GIFs or other similar technologies, as described below. These may be used to, among other things, track the actions of the Site’s users and compile statistics about the Site’s usage and response rates.

We may use Browser Derived Data and other data that does not identify you personally for any purpose, except where we are required to do otherwise under applicable law.

Browser Derived Data may also be provided to third parties that collect and index such data for analytical purposes. Such information is anonymized and aggregated so that no personal information is included or accessible; John Galt shares and uses it to better understand our candidates, markets and trends. Although we believe that each of the third parties to which we provide information employ reasonable and adequate data privacy and security measures, we can give no guarantees.

In some instances, we may combine Browser Derived Data with User Submitted Data (such as combining your name with your geographical location). If we combine any Browser Derived Data with User Submitted Data, the combined information will be treated by us as User Submitted Data as long as it is combined.

We may share, rent, sell or license Browser Derived Data regarding our users to third parties, including service providers, but not in a manner in which the recipient would be able to identify you personally.

Other Use and Disclosure

We also may use and/or disclose User Submitted Data, Browser Derived Data and/or Third Party Data as we believe to be necessary or appropriate to:

 

• comply with applicable law,
• respond to inquiries, requests and orders from public and governmental authorities,
• enforce this Privacy Policy and any terms of use governing the Site and our Services,
• protect our assets and operations and those of our affiliates, clients and partners,
• protect the rights, privacy, safety and property of John Galt, our affiliates, clients, partners, you and others,
• operate and maintain the security of the Site and our Services, including to detect, prevent and investigate the unauthorized use of or attacks on our computer systems or networks,
• allow us to pursue available remedies or limit the damages that we may sustain, as well as establish, exercise and defend legal claims,
• a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity (including in connection with any bankruptcy or similar proceedings), and
• as otherwise permitted by law.

As noted above, in certain situations we may be required to disclose personal data in response to lawful requests, inquiries or orders from public or governmental authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information, such as to comply with a subpoena, when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud or other illegal activity.

We cannot and do not assume any responsibility for the actions or omissions of third parties, including clients and governmental agencies, for the ways in which they may use or misuse information received from John Galt.

Retaining Information

We will retain your information when we have a legitimate business need to do so, including in connection with our relationship with you,, to provide requested Services, to comply with applicable legal, tax or accounting requirements, or as otherwise required or permitted to be maintained for other business purposes such as fraud prevention or preserving and defending our legal rights.

In the course of our operations we may use the information we have collected about you to create a profile about you. This profile may be used to identify employment opportunities we think may be of interest to you. Profiles of job applicants and employees whose assignments have ended will be maintained in the Company’s records to be potentially contacted about other employment opportunities.

We retain your personal information only for so long as needed or permitted considering the purpose(s) for which it was obtained. The criteria used to determine retention periods include but are not limited to:

• the length of time we have any ongoing relationship with your or a client,
• a period beyond such time if we have a legitimate internal business need, such as data analysis, and
• where a law requires us to retain information for a specified period, or retention is considered advisable for our legal position or protection.

We maintain technical, administrative and physical measures designed to protect sensitive personal and other confidential information from unauthorized access and use. Our third party vendors agree to keep the information we share with them confidential and to use the information only to perform the specific tasks requested of them.

If you are successful in being placed on assignment with a Company client, the information we collect and obtain about you both during the recruitment process and during your employment with us will become part of your employment record and maintained in accordance with our policies and applicable law governing personnel files.

When we have no ongoing legitimate business need to retain personal information, we will either delete or anonymize it. If this is not possible (e.g. because personal information has been stored in backup archives), we will securely store personal information and isolate it from any further processing until deletion is possible.

John Galt will delete your information upon verified request but may maintain a copy for audit and archival purposes only. This means you will not be considered or contacted about opportunities in the future.

Linked Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, security or other practices of any third party websites (if any) to which we may include a link on or are otherwise integrated with the Site. Such links are provided for your convenience only. We are not endorsing, in any manner, any of the linked sites that may be referenced in or linked to the Site, and John Galt specifically disclaims any responsibility if such third party sites do not provide adequate security for your personal information. We encourage you to read the terms of use and privacy policies of any such linked third-party site, as they may differ from ours. This Privacy Policy covers only the use of your information by John Galt.

Additionally, certain personal information may be made available to third parties using an Application Programming Interface, or “API.” Use of third party applications developed using our API, if any, are subject to the terms of use and privacy policies of such third party developers.

Remarketing and Retargeting

We may use third-party remarketing services (such as Google AdWords, AdRoll and Facebook) to advertise on third-party websites to previous visitors of the Site. It could mean that we advertise to previous visitors who haven’t completed a task on the Site, such as those who begin but do not submit an application. This could be in the form of an advertisement or posting on the Google search results page, Facebook, or various other websites within these networks or on the Internet generally. Any data collected will be used in accordance with this Privacy Policy and the privacy policies of these third-party remarketing services. You can set your preferences for how these services advertise to you by visiting the applicable opt-out page.

Cookies

A “cookie” is a small text file placed on a website visitor’s device to identify you and help us improve a visitor’s access to and use of the Site. John Galt uses cookies and similar tracking technologies to, among other things, store your preferences and settings, store information you provide to the Site, and authenticate you. Cookies also enable us to track and target the interests of users to enhance the experience of the Site. In addition, companies with which we may have relationships, like those that may deliver content to the Site, may utilize cookies for their own purposes.

You can control the data stored by cookies, and withdraw consent to cookies, by using browser-based cookie controls, which allow you to block or delete them, and also by notifying us of your desire not to be tracked by us using cookies (including opting out of receiving Internet-based advertising from us). If you choose to block cookies or similar technologies, some features of the Site may not be available to you.

Web Beacons and Analytics Services

Some of our webpages may contain electronic tags – known as web beacons – that we use to help deliver cookies to the Site and count users who have visited the Site, among other things. We may also include them and similar technologies in our electronic communications to determine whether you open and act on them.

In addition to placing web beacons on our own Site, we may work with companies to place our web beacons on their sites, and vice versa. Some uses for web beacons and other technologies (such as pixel tags and clear GIFs) are to help manage online and email advertising campaigns and strengthen the effectiveness of such campaigns. For example, if we or a vendor has placed a unique cookie on your computer, the vendor may use a pixel tag to recognize the cookie during your visit to the Site and learn which of our online advertisements brought you to the Site, and the vendor may provide us with such Browser Derived Data for our internal use. Please note we may link such Browser Derived Data provided to us by our vendors to User Submitted Data about you that we have previously collected. Such combined information will be treated as User Submitted Data hereunder as long as it is so combined, as noted above.

Security Measures

We employ a variety of commercially reasonable organizational, technical and administrative measures to protect User Submitted Data under our control and prevent its loss, misuse or unauthorized access or disclosure. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Consequently, we cannot guarantee or warrant the security of any User Submitted Data, which you transmit at your own risk. Please contact us if you believe your communications with, or information provided to, John Galt have been compromised or used or disclosed in violation of this Privacy Policy. Contact information is included below.

Access by Minors

Our Site is not intended for or directed to individuals under the age of 16. We request that these individuals not provide User Submitted Data through the Site. If you become aware that information has been submitted by or collected from a child under the age of 16, please contact us directly at:

John Galt Staffing, Inc.
77 South Bedford Street
Suite 325
Burlington, MA 01803
Email: legal@j-galt.com

IF YOU ARE A CALIFORNIA RESIDENT

If you are a California resident, we will adhere to and provide the rights granted to you under the California Consumer Privacy Act of 2018, as modified by the California Privacy Rights Act (referred to together in this Notice as the “Privacy Act”). This section of our Privacy Policy contains information required by the Privacy Act and supplements our Privacy Policy.

In addition, if you are a California resident applying to, or already employed by, the Company, important information is contained in this Notice: CA Notice regarding the personal information we may collect in connection with our provision of employment staffing services, which includes search, recruitment, screening and placement of candidates in temporary assignments and permanent jobs with our clients. Such Notice also supplements our Privacy Policy and should be read in conjunction with such policy.

Personal Information We May Collect

The table below shows the categories of personal information we may collect, the sources of such personal information, and the primary business or commercial purposes for which we may use such information for users of the Site in general. For all categories of personal information collected, we disclose personal information to our service providers and other third parties to help us accomplish the business and commercial purposes described below and in our Privacy Policy.

In general, “personal information” under the Privacy Act is information that identifies, relates to, describes or could reasonably be associated with or linked with you or your household. For example, it could include your name, social security number, email address, Internet browsing history, professional and employment information, and inferences from other personal information that could create a profile about your preferences and characteristics. Generally speaking, the contents of job applications, employee personnel records, and employee communications are all considered personal information under the Privacy Act.

For the table, the list of examples is illustrative only and is not intended to be an exhaustive list.

Personal information does not include publicly available information contained in government records, deidentified or aggregated consumer information, and information excluded from the Privacy Act’s scope such as health or medical information covered by the Health Insurance Portability and Accountability Act and personal information covered by sector-specific privacy laws like the Gramm-Leach-Bliley Act.

In all cases, we may use personal information to comply with applicable law or respond to legal process, respond to requests from public and governmental authorities, and in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity (including in connection with any bankruptcy or similar proceedings).

Sale

In the preceding 12 months, John Galt has not sold any personal information. In the event John Galt was to begin selling personal information as part of its business, we will become subject to the requirement to provide a clear and conspicuous “Do Not Sell My Personal Information” link on our Site that allows you to submit an opt-out request (see below). You are not required to create an account in order to submit your request.

You may also submit a request via email at legal@j-galt.com.

Your Privacy Act Rights

Access – The Right to Know

You have the right to request that we disclose what personal information we have collected about you (along with information regarding its use and disclosure) and, if applicable, sold, over the past 12 months upon appropriate verification.

Specifically, you may request that we disclose:

• the categories of personal information collected
• specific pieces of personal information collected
• the categories of sources from which we collected personal information
• the purposes for which we use the personal information
• the categories of third parties with whom we share the personal information, and
• the categories of information that we sell or disclose to third parties.

California residents who use the Site or otherwise contact John Galt to explore job opportunities therefore are entitled to access the employment-related information John Galt collects from and about them – such as employment history and educational background – and correct inaccurate personal information. They are also entitled to delete such personal information and opt out of the sale of personal information to third parties, discussed below. Further, employees, job applicants and contractors can restrict the use of sensitive personal information – such as Social Security number and financial account data– to specified business purposes or limited disclosure. John Galt only uses such sensitive personal information in connection with its legitimate business purposes, including search, recruitment, screening and placement services.

Deletion – The Right to Delete

You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete the information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the Privacy Act, including to:

• complete the transaction for which we collected the personal information from you, including placement in a temporary assignment or permanent job,
• detect security incidents and protect against malicious, fraudulent or illegal activity, or
• comply with a legal obligation.

Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Opt Out – The Right to Opt Out of Sale

Those covered by the Privacy Act have the right to request that businesses stop selling their personal information to third parties (“opt-out”). With some exceptions, businesses cannot sell your personal information after they receive your opt-out request unless you later provide authorization allowing them to do so again. Businesses must wait at least 12 months before asking you to opt back in to the sale of your personal information.

Freedom – The Right to be Free from Discrimination

Businesses cannot deny you goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your rights under the Privacy Act

Exercising Your Rights

To exercise the access and deletion rights described above, please submit a verifiable request by emailing us at legal@j-galt.com or sending us a request using the Contact Form, available under the “Contact” page on the Site.

As noted above, John Galt does not currently sell personal information. Should it do so, it will provide a clear and conspicuous “Do Not Sell My Personal Information” link on the Site. Make sure you submit your opt-out request through the “Do Not Sell My Personal Information” link. If the “Do Not Sell” link is not working, notify us in writing via email at legal@j-galt.com.

You do not have to create an account with John Galt to exercise your rights under the Privacy Act.

Applicants and employees seeking to exercise any of their rights under the Privacy Act may also do so by contacting John Galt’s corporate counsel at jausrotas@j-galt.com or (781) 273-9995.

Verifying Your Request

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. In the case of access and deletion, your request must be verifiable before we can fulfill such request.

Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We may ask for additional information, such as your email address and phone number, to validate your request before honoring it.

We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority.

Response Timing and Format

We will acknowledge requests exercising a consumer’s right to know, correct and/or delete information within 10 business days of our receipt of such request, and we will endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time (for up to an additional 45 days, and no more than 90 days in total), we will inform you of the reason and extension period in writing.

Requests to opt out (if and when applicable) and requests to limit the use of sensitive personal information will be honored within 15 business days of a verifiable request for same.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive, or manifestly unfounded.

Contacting Us

If you have any questions regarding our privacy practices as it relates to this Notice, please contact us via email at legal@j-galt.com with the subject line, “CA Privacy Act.”

Effective Date: January 1, 2023