CCPA Privacy Notice

Privacy Statement-California:

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“Privacy Statement”) supplements the information contained in the Privacy Policy, which is incorporated by reference as if set forth herein. This Privacy Statement applies solely to visitors, users, job applicants, independent contractors and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and other California privacy laws (collectively “CCPA”). Any terms defined in the CCPA and/or CPRA have the same meaning when used in this notice.

Whenever you visit our website, we will collect some information from you automatically simply by you visiting and navigating through this site, and some voluntarily when you submit information using a form on the website, enrol in or subscribe to our marketing communications, request information, or use any of the other interactive portions of our website. Through this website, we will collect information that can identify you and/or your activity.

Additionally, whenever you communicate, interact or do business with us, whether online or at any of our physical locations or facilities, or whether you are contracted to perform services for us or apply for a position of employment, we will be collecting personal information from you or about you in the course of our interaction or dealings with you.

This policy does not apply to our current and former employees and their family members, dependents, and beneficiaries; if you are a California resident who is a current or former employee of the Company or a family member, dependent, or beneficiary of any of our current or former employees, you may request access to our Employee Privacy Policy by sending an email to info@jbpco.com.

INFORMATION WE COLLECT

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). The categories of information set forth in the chart below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected but reflects a good faith belief that, to the best of our knowledge, some of that information may have been collected. In particular, we may have collected the following categories of personal information from consumers within the last 12 months:

Category	Examples	Disclosed Last 12 Months to	Sold or shared In Last 12 Months	Collected	Retention Period
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	A, D, E G, H, I, J, K, L	Not sold or shared	YES	Paper file maintained duration of employment plus 6 years. Electronic file maintained indefinitely
Personal Information	A name, signature, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.	A, D, E, G, H, I , J, K	Not sold or shared	YES	Paper file maintained duration of employment plus 6 years. Electronic file maintained indefinitely
Protected Classifications	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	D, H, K	Not sold or shared	YES	Paper file maintained duration of employment plus 6 years. Electronic file maintained indefinitely
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.		Not sold or shared	NO
Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	H, K	Not sold or shared	YES	While in use for identity verification
Account Information	Username and password for Company accounts and systems, and any required security or access code, password, or credentials allowing access to your Company accounts.	K, L	Not sold or shared	YES	Dayforce Username: permanent. Password while in use. IT Profile from 2 weeks up to 1 year based on user.
Mobile Device Data	Data identifying employee’s devices accessing Company networks and systems, including cell phone make, model and serial number, cell phone number, and cell phone provider.	K, L	Not sold or shared	YES	Duration of employment plus 2 weeks.
Online Portal & Mobile App Access & Usage Info	Username and password, account history, usage history, file access logs, and security clearance level.	K, L	Not sold or shared	YES	Duration of employment plus 2 weeks.
Pre-Hire Information	Information provided in your job application or resume, information gathered as part of background screening and reference checks, pre-hire drug test results, job interview notes by persons conducting job interviews for the Company, information contained in candidate evaluation records and assessments, information in work product samples you provided, voluntary disclosures by you, and Wage Opportunity Tax Credit (WOTC) information.	A, D, G, H, J, K	Not sold or shared	YES	Paper file maintained duration of employment plus 6 years. Electronic file maintained indefinitely
Internet or Other Similar Network Activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	L	Not sold or shared	YES	Duration of employment plus 2 weeks
Geolocation Data	Physical location or movements.	K	Not sold or shared	YES	Duration of employment plus 2 weeks
Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	K	Not sold or shared	YES	60 days.
Professional or Employment-Related Information	Current or past job history or performance evaluations.	A, D, E, G, H, I, J, K	Not sold or shared	YES	Paper file maintained duration of employment plus 6 years. Electronic file maintained indefinitely
Non-Public Education Information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	J, K	Not sold or shared	YES	Paper file is maintained for duration of employment plus 6 years. Electronic file is maintained indefinitely.
Inferences Drawn From Other Personal Information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.		Not sold or shared	NO
Professional Related Information	Information on independent contractors contained in tax forms/1099 forms, safety records, licensing and certification records, and performance records and information related to services provided by independent contractors, including in statements of work.	D, H, K	Not sold or shared	YES	Paper file is maintained for duration of employment plus 6 years. Electronic file is maintained indefinitely.
Facility & Systems Access Information	Information identifying you, if you access our secure company facilities, systems, networks, computers, and at what times, using keys, badges, fobs, login credentials, or other security access method.	K	Not sold or shared	YES	Duration of employment plus 60 days.
Medical and Health Information	Information related to symptoms, exposure, contact tracing, diagnosis, testing, or vaccination for infectious diseases (e.g., COVID-19), pandemics, or other public health emergency.	D, H, K	Not sold or shared	YES	Duration of employment plus 6 years, unless related to hazardous exposure records required by OSHA to be retained for at least 30 years. Electronic files are maintained indefinitely.

Of the above categories of Personal Information, the following are categories of Sensitive Personal Information LEER may collect from or about consumers, job applicants or independent contractors:

Personal Identifiers (social security number, driver’s license or state identification card number, passport number)
Account Information (LEER account log-in, in combination with ay required security or access code, password or credentials allowing access to the account)
Protected classification characteristics under California or federal law (racial or ethnic origin, religious or philosophical beliefs, union membership or sexual orientation)
Biometric information (used for the purpose of uniquely identifying you)
Geolocation data (IP address and/or GPS location, latitude and longitude)
Medical and health information
Contents of Personal Communications (e.g., contents of mail, email and text messages where the Company is not the intended recipient).

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope, including, without limitation:

health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Information a business reasonably believes is lawfully made available to the general public by the consumer, job applicant or independent contractor, or from widely distributed media.
Information made available by a person to whom the consumer, job applicant or independent contractor has disclosed the information if the consumer, job applicant or independent contractor has not restricted the information to a specific audience.

SOURCES FROM WHICH WE MAY COLLECT INFORMATION

We obtain the categories of personal information listed above from the following categories of sources:

Directly from our customers.
Indirectly from our customers. For example, through information we collect from our clients in the course of providing products and/or services to them.
Directly and indirectly from activity on the Site. For example, from submissions through our website portal or website usage details collected automatically.
From third parties that interact with us in connection with our products and services.
Our employees, contractors, vendors, suppliers, guests, visitors, other consumers, and customers based on their interactions with them (if any).
Surveillance cameras at our physical locations.
Lead generators and referral sources.
Credit and consumer reporting agencies.
HR support vendors.
Recruiters.
Staffing agencies.
Social media platforms.
Company-issued computers, electronic devices and vehicles.
Company systems, networks, software applications and databases logged into, interacted with or otherwise used during the employment application process.
Vendors engaged by the Company to manage or host company systems, networks, software applications and databases.
Personal references and former employers regarding job applicants.
Schools, universities or other educational institutions attended by job applicants.
Friends, family or colleagues who emailed job postings to possible job applicants from LEER’s application platform or careers page.

POTENTIAL RECIPIENTS OF PERSONAL INFORMATION WE MAY COLLECT

We may disclose, personal information to the following categories of service providers, contractors or third parties:

Financial institutions
Lead providers.
Product manufacturers/administrators.
Government agencies.
Promotional or other fulfilment vendors.
Marketing support vendors and vendors that support managing or hosting the website.
Transaction support vendors (e.g., check guaranty, payment processors).
Data analytics vendors.
Professional employer organizations, recruiting firms and/or staffing agencies.
Consumer reporting agencies or credit reporting agencies.
Talent acquisition management systems and other vendors providing services for purposes of human resources information (HRIS) and management of job applicant data and recruiting process.
Security and risk management vendors, including IT, cybersecurity and privacy vendors and consultants.
Corporate customers (meaning an entity, as opposed to a natural person, that purchases, leases or finances any of our products or services).
Original equipment manufacturers (OEM) (suppliers and makers of the products we sell or lease to our customers).

USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, fulfilling one of your transactions.
To provide you with information, products or services that you request from us.
To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collections.
To improve the Site and present its contents to you.
For testing, research, analysis and product development.
As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
To fulfill or meet the purpose for which you provided the information.
To process and submit financing applications, including to apply for credit, or credit pre-qualification.
To process, complete, and maintain records on transactions.
To provide warranty coverage on products and services.
To retain your selection for Text opt in/opt out to ensure customers who opted out are not sent any text messages.
To provide and communicate recall notifications to customers.
To schedule, manage and keep track of customer appointments.
To complete appraisals.
To maintain records of when customers decline a service or sale.
To respond to consumer inquiries, including requests for information, customer support online, Live Chat on the website, phone calls, and in-store inquiries.
To provide interest-based and targeted advertising.
To contact you by email, telephone calls, mail, SMS, or other equivalent forms of communication regarding updates or informative communications related to the functionalities, services, or other information you requested or asked the Company to provide to you.
To improve user experience on our website.
To understand the demographics of our website visitors.
To detect security incidents.
To debug, identify, and repair errors that impair existing intended functionality of our website.
To protect against malicious or illegal activity and prosecute those responsible.
To verify and respond to consumer requests.
To prevent identity theft.
JOB APPLICANT PURPOSES:

To fulfill or meet the purpose for which you provided the information. For example, if you share your name and contact information to apply for a job with the Company, we will use that Personal Information in connection with your candidacy for employment.
To comply with local, state, and federal law and regulations requiring employers to maintain certain records, as well as local, state, and federal law, regulations, ordinances, guidelines, and orders relating to infectious diseases, pandemics, outbreaks, and public health emergencies, including applicable reporting requirements.
To evaluate your job application and candidacy for employment.
To obtain and verify background check and references.
To communicate with you regarding your candidacy for employment.
To permit you to create a job applicant profile, which you can use for filling out future applications if you do not get the job you are apply for.
To keep your application on file even if you did not get the job applied for in case there is another position for which we want to consider you as a candidate even if you do not formally apply.
To evaluate and improve our recruiting methods and strategies.
To engage in lawful monitoring of job applicant activities and communications when they are on Company premises, or utilizing Company internet and WiFi connections, computers, networks, devices, software applications or systems.
To engage in corporate transactions requiring review or disclosure of job applicant records subject to non-disclosure agreements, such as for evaluating potential mergers and acquisitions of the Company.
To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company related to recruiting or processing of data from or about job applicants.
To improve job applicant experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
To reduce the risk of spreading infectious diseases in or through the workplace.

INDPENDENT CONTRACTOR PURPOSES:

To fulfill or meet the purpose for which you provided the information.
To comply with state and federal law and regulations requiring businesses to maintain certain records (accident or safety records, and tax records/1099 forms).
To engage the services of independent contractors and compensate them for services.
To evaluate, make, and communicate decisions regarding an independent contractor, including decisions to hire and/or terminate.
To grant independent contractors access to secure Company facilities, systems, networks, computers, and equipment, and maintain information on who accessed such facilities, systems, networks, computers, and equipment, and what they did therein or thereon.
To implement, monitor, and manage electronic security measures on independent contractor devices that are used to access Company networks and systems.
To evaluate, assess, and manage the Company’s business relationship with vendors, service providers, and contractors that provide services to the Company.
To improve user experience on Company computers, networks, devices, software applications or systems, and to debug, identify, and repair errors that impair existing intended functionality of our systems.
To reduce the risk of spreading infectious diseases in or through the workplace.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We do not and will not sell or share your personal information in exchange for monetary or other valuable consideration. We do not share your personal information for cross-context behavioral advertising.

In the preceding 12 months, we have not sold or shared any personal information.

DISCLOSING PERSONAL INFORMATION

We may disclose your personal information to a third party for a business purpose, as noted in the table above. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We do not and will not use or disclose your sensitive personal information for purposes other than the following:

To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information.
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
To ensure the physical safety of natural persons.
For short-term, transient use.
To perform services on behalf of the Company.
To verify or maintain the quality or safety of a product, service or device that is owned, manufactured, manufactured for, or controlled by the Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the Company.
For purposes that do not involve inferring characteristics about the consumers, contractors, and applicants.

Retention of Personal Information

We will retain each category of personal information in accordance with our established data retention schedule as indicated above. In deciding how long to retain each category of personal information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.

We apply our data retention procedures on an annual basis to determine if the business purposes for collecting the personal information, and legal reasons for retaining the personal information, have both expired. If so, we will purge the information in a secure manner.

Third Party Vendors

We may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail services and running special promotions. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose. Subscribers or site visitors will never receive unsolicited e-mail messages from vendors working on our behalf.

Business Transfers

In the event we sell or transfer a particular portion of its business assets, information of consumers, contractors and applicants may be one of the business assets transferred as part of the transaction. If substantially all our assets are acquired, information of consumers, contractors and applicants may be transferred as part of the acquisition.

Compliance with Law and Safety

We may disclose specific personal and/or sensitive personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public.

Use of Cookies and Other Tracking Technologies

Cookies are small files that a website may transfer to a user’s computer that reside there for either the duration of the browsing session (session cookies) or on a permanent, until deleted, basis (persistent cookies) that may be used to identify a user, a user’s machine, or a user’s behavior. We make use of cookies under the following circumstances and for the following reasons:

Provide you with services available through the website and to enable you to use some of its features
Authenticate users and prevent fraudulent use of user accounts
Identify if users have accepted the use of cookies on the website
Compile data about website traffic and how users use the website to offer a better website experience
Understand and save visitor preferences for future visits, such as remembering your login details or language preference, to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the website
Track your browsing habits to enable us to show advertising which is more likely to be of interest to you, including advertising by third parties on our website

You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of or even block the website. You can prevent saving of cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions will not be available on our website when use of cookies is deactivated. Check the settings of your browser. Below you can find some guidance:

Do Not Track (DNT) is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals.

External Links

Our website contains links to other sites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Privacy Policy of any site you visit via a link from our website.

Passwords

The personal data record created through your registration with our website can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.

Children Under the Age of 16

We do not knowingly sell or share the personal information of consumers under 16 years of age.

How We Protect the Information that We Collect

The protection of the information that we collect about visitors to this website is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:

We keep automatically collected data and voluntarily collected data separate at all times.
We use internal encryption on all data stores that house voluntarily captured data.
We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
We restrict access to private information to those who need such access in the course of their duties for us.

International Visitors

We do not target, market to, or offer our products or services to consumers outside of the United States. You agree not to submit your personally identifiable information through the website if you reside outside the United States. If we become aware that a person residing inside the European Economic Area, European Union, Great Britain, or Switzerland has submitted their personal information to us, we will delete it.

Rights Under the CCPA and CPRA

This section of the Privacy Policy applies only to California residents who are natural persons. If you are a California resident, you have the following rights pursuant to the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected about you going back to January 1, 2022, unless doing so would be impossible or involve disproportionate effort, or unless you request a specific time period, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we disclose or have disclosed your personal information. share or have shared your personal information;
Right to Access. The right to request, up to 2 times in a 12-month period, that we disclose to you, free of charge, the specific pieces of personal information we have collected about you going back to January 1, 2022, unless doing so would be impossible or involve disproportionate effort, or unless you request a specific time period;
Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
Right to Correct. The right to request that we correct inaccurate personal information (to the extent such an inaccuracy exists) that we maintain about you;
Right to Opt-Out. The right to opt-out of the selling or sharing of your personal information to third parties (note: we do not currently sell or share your personal information);
Right to Limit. The right to limit the use or disclosure of your sensitive personal information;
The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and
The right to not be discriminated or retaliated against for exercising any of the above rights, including an applicant’s and independent contractor’s right not to be retaliated against for exercising the above rights.

You can submit any of the above types of consumer requests through any of the options below:

Calling us at (833) 579-9800.
Emailing us at info@jbpco.com.
Complete a paper form, which can be requested through Human Resources at your workplace.
Complete an on-line request form on our website at www.leer.com.

How We Will Verify That it is Really You Submitting the Request

If you are a California resident, when you submit a Right to Know, Right to Access, Right to Delete, or Right to Correct request through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular records in our possession, which depends on the nature of your relationship and interaction with us. For example, we may need you to provide your name, email, phone number, IP address, browser ID, amount of your last purchase with the business, and/or date of your last transaction with the business.

Responding to Your Right to Know, Right to Access, Right to Delete, and Right to Correct Requests

Upon receiving a verifiable request from a California resident, we will confirm receipt of the request no later than 10 business days after receiving it. We endeavor to respond to a verifiable request within forty-five (45) calendar days of its receipt. If we require more time (up to an additional 45 calendar days, or 90 calendar days total from the date we receive your request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

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

For a request to correct inaccurate personal information, we will accept, review, and consider any documentation that you provide, and we may require that you provide documentation to rebut our own documentation that the personal information is accurate. You should make a good-faith effort to provide us with all necessarily information at the time that you make the request to correct. We may deny a request to correct if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. If we deny your request to correct, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.

Responding to Your Request to Opt-Out of the Selling or Sharing of Your Personal Information

We will act upon a consumer request to opt-out within fifteen (15) days of its receipt. We will notify all third parties to whom we have sold or shared personal information of your request and instruct them to comply with the request within the same time frame. We will notify you when this has been completed by mail or electronically, at your option.

A request to opt-out need not be a verifiable consumer request. However, we may deny a request to opt-out if we have a good faith, reasonable, and documented belief that a request to opt-out is fraudulent. If we deny your request to opt-out, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.

Responding to Your Request to Limit the Use of Sensitive Personal Information

We will act upon a request to limit the use of sensitive personal information within fifteen (15) business days of its receipt. We will notify all third parties that use or disclose sensitive personal information of your request to limit and instruct them to comply with the request within the same time frame. We will notify you when this has been completed by mail or electronically, at your option.

A request to limit need not be a verifiable request. However, we may deny a request to limit if we have a good faith, reasonable, and documented belief that a request to limit is fraudulent. If we deny your request to limit, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.

If You Have an Authorized Agent:

If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf. To do so, you must either (a) execute a valid, verifiable, and notarized power of attorney or (b) provide other written, signed authorization that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.

Other California Privacy Rights

The California Civil Code permits California Residents with whom we have an established business relationship to request that we provide you with a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an email to info@jbpco.com, or write to us at the address listed below. Please mention that you are making a “California Shine the Light” inquiry.

Consent to Terms and Conditions

By using this website, you consent to all terms and conditions expressed in this Privacy Policy.

Consumers With Disabilities

This policy is in a form that is accessible to consumers with disabilities.

Changes to Our Privacy Policy

As our services evolve and we perceive the need or desirability of using information collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check our website frequently to see the current Privacy Policy in effect and any changes that may have been made to them. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy and the revised effective date on this website. Please check back here periodically or contact us at the address listed at the end of this Privacy Policy.

**This policy was last updated June 2023.

Questions About the Policy

This website is owned and operated by LEER Group. If you have any questions about this Privacy Policy, please contact us at info@jbpco.com or call (833) 579-9800.