FJ Management Privacy Policy

Privacy Notice

Revised 12/03/2024 and effective 12/03/2024

This is the Privacy Notice (the “Privacy Notice” or the “Notice”) of FJ Management Inc. (the “Company,” “we,” “us,” “our”, or “FJ Management”). This Privacy Notice is here to help you understand how we collect, process, and share your personal information when you interact with our websites, online services, applications, and business operations and services (our “Services” or “Site” or “Sites”). We also describe our security practices with respect to your personal information, as well as your rights and choices with respect to how we process that personal information. Please read this Privacy Notice carefully.

This Notice explains:

The types of information we collect about you through our websites, online services as well as from third party sources and offline in connection with our Services;
How we use and protect that information;
The types of information we may share with others and under what circumstances;
Our security practices related to your information;
The rights you have regarding our data handling practices; and
Other practices related to the handling of personal information.

By using our Services and/or submitting personal information to our Sites, you are accepting and consenting to the practices and uses described in this Privacy Notice. This Privacy Notice is not a contract.

How to Contact Us with Questions or Requests

If you have questions, comments or concerns about our Privacy Notice and privacy practices, or if you wish to issue a request to exercise your rights where applicable by law, please contact us as follows: email at: [email protected] or call at: (877) 399-1130.

When This Privacy Notice Applies

This Privacy Notice applies to any information we collect when you interact with the Sites through social media or other websites and online services, as well as to information that we collect offline (e.g., via paper or telephone call) and combine with information collected on our Sites. It does not apply to non-Company, websites and mobile applications that may link to or be linked from our Sites. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

This Privacy Notice does not apply to any subsidiary of FJ Management that has its own separate privacy policy and notice. Please review the separate privacy policies and notices of any subsidiary of FJ Management found on their individual webpages.

This Privacy Notice does not apply to “personal financial information,” including personal information governed by the Gramm-Leach-Bliley Act, or “protected health information” such as medical records, even if we collect such information through our Sites or offline.

Changes to this Privacy Notice

We may make changes to this Privacy Notice from time to time. We will post any changes to our Privacy Notice on this Site. Such changes will become effective when they are posted. Your continued use of our Sites and Services following the posting of any changes will mean you accept those changes.

Information We Collect From or About You

Below we describe the different types of information we collect from you, including from the devices you use, when you interact with our Sites and/or take advantage of our Services.

Information You Give Us: We collect and maintain personal information about you from many sources to understand and meet your needs, provide our Services, manage our business, and for other purposes disclosed to you. We collect and store any information you enter on our Sites, provide to us in written form, or communicate to us verbally. This may include:

Personal identifiers such as your name, address, email address, account name, social security number, driver’s license number, passport number;
Personal or physical characteristics protected by federal or state law, such as gender, race, ethnicity, age;
Biometric information;
Audio, electronic, visual, or similar information; and
Additional information, as necessary.

This information may also include information you provide during a registration/sign-up process, if any, including account numbers or other identifiers needed to link to your bank account. Currently, there are no services on our site that would require such information.

We also collect personal information that you submit to us when applying for a job via one of our Sites (including any CV or résumé that you upload to the website) and, if you are hired, information regarding your employment, performance, and other employment related information. This information will be collected and processed, where permissible by relevant, applicable law. This includes the following information, without limitation:

Recruitment information: Cover letter, resume, educational background, professional background, sex/gender, date of birth, ethnicity, and nationality.
Career and job performance information: Job level/position, details of skills and experience from the referrals provided.
Background check information: Information about judicial disputes and criminal records.
Information publicly available: Information about you from publicly available social media profiles, such as content from external job bulletin boards.
Employee Personnel File: If you are hired as an employee, information collected and maintained during your period of employment and for a period after your period of employment terminates.

Information Collected Automatically: When you interact with our Sites, certain information may be automatically collected. This information includes computer and connection information, such as statistics on your page views, traffic to and from our Sites, referral URL, your IP address, and device identifiers. This information also may include your web log information, how you searched for our Sites, the websites you click on from our Sites or emails, whether and when you open our emails, and your browsing activities across other websites.

Much of this information may be collected through Cookies, web beacons, and other tracking technologies, as well as through your web browser or device (e.g., IP address, MAC address, browser version, etc.). Most web browsers automatically accept Cookies but, if you prefer, you can usually modify your browser setting to disable or reject Cookies. If you delete your Cookies or if you set your browser to decline Cookies, some features of our Sites may not be available, work, or work as designed.

Location Information: When you interact with our Sites, we may collect information about your location and your device. Some of this information may be general, such as the state or city associated with your zip code, while some of this information may be more precise, such as information associated with your device. Location information allows us to provide location-based services.

Information from Social Media and Third Party Services: In the event you connect to, authenticate through, or interact with us or our Sites using a social media platform (such as by clicking on a social media icon linked from our Sites, or on a link to our Sites) or third party service (such as a Google account or a reservation service provider), we may collect information, including personal information, available through the service or the service’s application programming interfaces (APIs). This information may include your name, account ID or username, contact details, email address(es), information related to your contacts, calendars, location information, profile picture, the contents of your posts or other communications, and other information the platform or third-party service makes available. If you choose to log in to your account with or through a social networking service or third-party service, we and that service may share certain information about you and your activities. You should check your privacy settings on these platforms and third party services to understand what information is made available to us, and you may be able to change the settings for these platforms or services to prevent, limit or otherwise control the information made available to us.

Information related to Minors: The Company does not knowingly collect information directly from minors—persons under the age of 16, or another age as defined by law—via our Sites or offline, other than when required to comply with the law or for safety or security reasons.

If you are a parent or guardian of a minor who has provided information without your knowledge or consent, you may submit a request to remove the minor’s information by calling Privacy Customer Service at (877) 399-1130 or emailing us at [email protected].

How We Use Information We Collect From or About You

We may use information you give us or information we collect about you to:

Communicate with you, including to respond to your inquiries and fulfill your requests;
Provide, maintain, personalize, optimize, and improve our Sites, including research and analytics regarding use of our Sites, social media platforms and third-party services, or to remember you when you leave and return to our Sites;
Provide and improve our products and services, including to provide you with online account management tools, services, to process any transactions you request, or to authenticate your identity;
Deliver advertising, including interest-based advertising on our Sites and other websites and applications;
If applicable, evaluate your application for employment with the Company, communicate with you about your application, conduct any necessary or appropriate background checks, comply with our diversity policy, manage any aspects of your prospective employment relationship with the Company and verify personal information by contacting your references;
Comply with legal, regulatory or fiscal obligations;
Detect, investigate, and prevent activities that may violate our policies or be fraudulent; and/or
Share your information at your direction or request, or when you otherwise consent.

We may combine information that you provide to us or information that we collect automatically with other information we obtain from our business records, including your use of websites and applications or purchase of products and services provided by the Company and, where applicable, your preferences and other personal characteristics. We also may use or combine information that we collect with information we obtain from third parties, including demographic information and other attributes, such as census data, purchasing data, demonstrated interests, loyalty programs, organizational affiliations and customer lists. Additionally, information collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected.

Cookies, Tracking and Interest-Based Advertising

Cookie Notice: Cookies consist of portions of code installed in the browser that assist the website owner in providing the website services according to the purpose described. The FJ Management Inc. website does not store Cookies on your computer. Some of the purposes for which Cookies are installed may also require your consent.These Cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. You accept the use of Cookies by closing or dismissing this notice, by clicking a link or button or by continuing to browse this website. If you decline to accept the use of Cookies, your information won’t be tracked when you visit this website. A single cookie will be used in your browser to remember your preference not to be tracked.

The help function of your browser should contain instructions on how to set your computer to accept all cookies, to notify you when a cookie is issued or to not receive cookies at any time. If you set your device to not receive cookies at any time, certain personalized services cannot be provided to you, and accordingly, you may not be able to take full advantage of all of our features.

The Company uses the information you make available to us when you interact with our Sites to provide you with advertising and offers that are more relevant to you. We partner with third party advertising companies to provide advertisements on our Sites, as well as on other websites and applications about our products and services that may be of interest to you. Some of our Sites may also include advertisements for unaffiliated products and services. The advertisements you see may be based on information collected through Cookies, web beacons and other tracking technologies from our Sites and on other third-party websites you visit and mobile applications you use that participate in our advertising networks. These third parties may use persistent identifiers to track your Internet usage across other websites and mobile applications in their networks beyond our Sites. While the Company will not share information that personally identifies you with unaffiliated third parties for their own uses, such third parties may, with sufficient data from other sources, be able to personally identify you.

You can learn more about ad serving companies and the options available to limit their collection of use of your information by visiting the websites for the Network Advertising Initiative and the Digital Advertising Alliance, the privacy policy for Pegasus Solutions Companies, our webmaster, the webpages for Facebook’s ad preferences tool through your device settings and by resetting the advertiser ID on your device. For more information about how to change these settings go to:

Apple: Apple Opt-Out

Android: Android Opt-Out

Windows: Microsoft Opt-Out

Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Sites or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your Cookies, you may also delete your opt-out preferences.

We use third parties to provide analytics services about your use and interaction of our Sites, including Google Analytics, a web analytics service provided by Google, Inc. Google Analytics and our other third party service providers and partners use Cookies or other tracking technologies to help us analyze how users interact with and use our Sites, compile reports on our Sites’ activity, and provide other services related to our Sites’ activity and usage. The technologies used by these third parties may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. Our Sites do not use Google Analytics or other third-party services to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here. The information generated by Adobe Analytics will be transmitted to and stored by Adobe and will be subject to Adobe’s privacy policies. To learn more about Adobe’s partner services and to learn how to opt out of tracking of analytics by Adobe, click here.

Your browser may include “Do Not Track” functionality. At this time, the Company does not respond to browser “Do Not Track” signals.

How We Share Information About You

We may share your information:

With companies who work on our behalf to help us provide and support our Sites and our products and services. We require these service providers to treat all information we provide as confidential and to use it only for providing the services for which they have been;
To provide you products and services, as well to send you information about other products and services we think you may be interested in;
To create aggregated or de-identified data that does not identify you. Once the data is aggregated or de-identified, we may use it for any purpose permitted by law and we may share it with third parties for their own uses; and/or
With third parties so that they may communicate with you about our products and services, as well as to deliver marketing communications, including emails, newsletters, offers tailored to you, and other materials that they believe may be of interest to you.

We may change our ownership or corporate organization. We may transfer to another entity or its affiliates or service providers some or all of the information we hold about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Notice.

We may use or disclose information about you if required to do so by law or on the good-faith believe that such sharing is necessary to (a) conform to applicable law or comply with legal process served on us or our Sites; (b) protect and defend our rights or property, our Sites, or our users; or (c) act to protect the personal safety of our employees and agents, other users of our Sites, or members of the public.

Aggregation Websites: Other companies offer websites and services that allow you to consolidate account information from multiple sources. To do this, those companies might ask you for your account credentials. The Company is not responsible for your use of such websites and services.

If you provide account credentials or other details about your account to such website or services, the Company will consider that you have authorized the website or service to access your account information. If you decide to revoke the authority you have given to an aggregation website or service, we strongly recommend that you change your password for the Sites to ensure that your account is inaccessible to the aggregation website or service.

How We Secure the Information We Collect From or About You

We use a combination of reasonable physical, technical, and administrative safeguards to protect the information we collect through our Sites and offline. In the event your personal information is shared, the Company will take a reasonable approach to prevent the unauthorized use of personal information.

While we use these precautions to safeguard your personal information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Retaining Your Information: In general, we do not keep personal information longer than is necessary for the purpose or purposes for which the Information was originally collected and processed.

If required, we may retain your personal information where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Users Outside of the United States: If you use our Sites outside of the United States, you understand and consent to the transfer of information about you, and the collection, processing, and storage of information about you, in the United States and elsewhere. The laws in the U.S. and these countries regarding personal information may be different than the laws of your state or country.

Your Rights Regarding Your Personal Information

Applicable law may grant you various rights regarding your personal information based on your location. See specific rights below regarding California, Colorado, Nevada and Washington. You have the right to update any of your personal information and you have the right to withdraw your consent or opt-out at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you, such as location-based services, personalizing or making relevant certain types of advertising, or other services conditioned on your consent or choice not to opt-out.

Certain rights requests must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your personal information. We may require that you provide the email address we have on file for you (and verify that you can access that email account) and we may request additional information from you. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

Text Messages

Opt-in Consent: By submitting your phone number to the Company or on its Sites, you are authorizing the Company to send you text messages and notifications. Message/data rates apply. Reply STOP to unsubscribe to a message sent from the Company. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes.

Website Notice of Accessibility

The Company is committed to facilitating the accessibility and usability of our Services for all individuals with disabilities. We continue to improve accessibility to our digital services and strive to create an accessible and barrier-free environment by making reasonable efforts to meet Level AA design standards recommended by the World Wide Web Consortium (W3C) in its Web Content Accessibility Guidelines (WCAG) 2.0.

Please be aware that we view accessibility as an ongoing effort and are continually seeking solutions that will ensure accessibility to all users. As such, our team tests our digital services on a periodic basis with assistive technologies.

For the best experience, we recommend using the most current version of any browser and assistive technology application. We further recommend trying different browsers with your assistive technology to determine which combination works best for you. The use of the version of the browser or assistive technology released immediately prior to the latest version also should provide a good user experience.

Please contact us at [email protected] if you are experiencing issues with the accessibility of our Services, or if you have specific questions or concerns about the accessibility of any particular page or section of any of our digital services. If you do encounter an accessibility issue, please be sure to specify the web page or section of the Mobile App in your email, and we will make all reasonable efforts to make that page or section accessible for you.

Additional State Rights, Including Your California Privacy Rights

California, Colorado and Other U.S. State Privacy Rights

Under the California Consumer Privacy Act (“CCPA”), the Colorado Privacy Act, and other state privacy laws, residents of certain US states may have the following rights, subject to regional requirements, exceptions, and limitations.

Confirming Processing: Right to confirm whether we process your personal information.

Access/Know: Right to request any of following: (1) the categories of personal information we have collected, sold/shared, or disclosed for a commercial purpose; (2) the categories of sources from which your personal information was collected; (3) the purposes for which we collected or sold/shared your personal information; (4) the categories of third parties to whom we have sold/shared your personal information, or disclosed it for a business purpose; and (5) the specific pieces of personal information we have collected about you.

Portability: Right to request that we provide certain personal information in a common, portable format.

Deletion: Right to delete certain personal information that we hold about you.

Correction: Right to correct certain personal information that we hold about you.

Opt-Out (Sales, Sharing, Targeted Advertising, Profiling): Right to opt-out of the following:

If we engage in “sales” (as defined by applicable law) of personal information, you may direct us to stop such selling.
If we engage in Targeted Advertising (aka “sharing” of personal information or cross-context behavioral advertising,) you may opt-out of such processing.
If we engage in certain forms of “profiling” (e.g. profiling that has legal or similarly significant effects), you may opt-out of such processing.

Opt-in/Opt-out of Sale/Sharing of Minors’ Personal Data: To the extent we have actual knowledge that we collect or maintain personal information of a minor under age 16 in California, those minors must opt in to any sales/sharing of personal information (as defined under CCPA), and minors under the age of 13 must have a parent consent to sales/sharing of personal information. All minors have the right to opt-out later at any time.

Non-Discrimination: California residents have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.

List of Direct Marketers: California residents may request a list of personal information we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.

Remove Minors’ User Content: Residents of California under the age of 18 can delete or remove posts using the same deletion or removal procedures described above, or otherwise made available through the digital services. If you have questions about how to remove your posts or if you would like additional assistance with deletion, contact us using the information below. We will work to delete your information, but we cannot guarantee comprehensive removal of that content or information posted through the digital services.

Submission of Requests: If you have any questions or wish to appeal any refusal to take action in response to a rights request (if the right of appeal is granted by your state), contact us at [email protected]. We will respond to any request to appeal within the period required by law:

You may email us at: [email protected]
You may call us at: (800) 789-4455. You will be directed to leave a voicemail where you will provide your email address, phone number or address, along with your request.

To limit the use and disclosure of Precise Location Data, update your preferences for location data using your device’s settings menu, or disable WiFi, Bluetooth, or other interfaces you use to interact with our digital services

California/CCPA Required Disclosures

Categories of Personal Data Disclosed for Business Purposes: For purposes of the CCPA, we have disclosed to Service Providers for “business purposes” in the preceding 12 months the following categories of Personal Data, to the following categories of recipients:

Category of Personal Data	Category of Recipients
Identity Data	Service Providers & Agents; Partners; Corporate Events; Legal Disclosure, Data Aggregators
Contact Data
Device/Network Data
General Location Data
Inference Data
Transaction Data
User Content
Audio/Visual Data	Service Providers & Agents; Corporate Events; Legal Disclosure
Sensitive Personal Information: Government ID Data; Payment Data	Service Providers & Agents; Corporate Events; Legal Disclosure

Categories of Personal Data Sold, Shared, or Disclosed for Commercial Purposes: For purposes of the CCPA, we have “sold” or “shared” in the preceding 12 months the following categories of Personal Data in the, to the following categories of recipients:

Category of Personal Data	Category of Recipients
Identity Data	Service Providers & Agents; Partners; Data Aggregators
Contact Data
Device Network Data
General Location Data
Inference Data
Transaction Data
User Content

Categories of Sensitive Personal Data Used or Disclosed: For purposes of CCPA, we may use or disclose the following categories of Sensitive Personal Data Government ID Data; Payment Data; Precise Location Data; Log-in Data. However, we do not sell or share Sensitive Personal Data, or use it for purposes other than those listed in CCPA section 7027(m).

Nevada Privacy Rights

The Nevada Revised Statutes (NRS 603A.300 et seq.) permit a Nevada consumer to direct an operator of an Internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. You may submit a request pursuant to this directive by emailing us at [email protected] re: Nevada Privacy Rights.

Washington State – Consumer Health Data Privacy Policy

Categories of Consumer Health Data We Collect: We collect the following categories of personal information linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status (“Consumer Health Data”) as defined under Washington’s My Health My Data Act, for the following purposes:

Categories of Consumer Health Data	Purpose for Collection	How data will be used
Precise location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies;	When you access or use our Sites or Mobile AppsMarketing Communications	We use Precise Location Data with your consent: To provide contextual information to you, such as the distance to your nearest Store, or to show you content related to your location.As necessary to customize, deliver, and otherwise process marketing communications, and in order to tailor certain communications to individuals’ preferences and requests.In connection with our legitimate business interests, such as, creating aggregate information about users’ location and patterns, which we use to personalize, optimize, and improve our Site, and for our other Business Purposes and Commercial Purposes (which may include data sales/sharing).
Data that identifies a consumer seeking “health care services” as defined under Washington’s My Health My Data Act, also referred to as “Identity Data;”	When You Visit Our Stores When you access or use our Sites or Mobile AppsWhen You Make an Online Purchase	We use Identity Data as necessary : In connection with certain legitimate business interests in verifying your identity;For authentication and security purposes; andHelping us to ensure our customers are genuine and to prevent fraud;to initiate or fulfill your requests through our Website;to ensure the security of our Services;to prevent fraud;to providing you with information about our Services;to contact you about administrative matters;to manage and respond to any queries or complaints you make or any correspondence you send us;in connection with our Business Purposes; We may process Identity Data, for Commercial Purposes (which may include data sales/sharing).
Any information that we or our respective processor, processes to associate or identify you with data described above that is derived or extrapolated from non-health information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning), also referred to as “Inference Data.”	When You Visit Our Stores When you access or use our Sites or Mobile AppsWhen You Make an Online Purchase Marketing Communications Feedback and Surveys	We use Inference Data as necessary to: to provide contextual information to you, such as the distance to your nearest Store, or to show you content related to your location.to customize, deliver, and otherwise process marketing communications, and in order to tailor certain communications to individuals’ preferences and requests.for our Business Purposes and Commercial Purposes (which may include data sales/sharing), for example, to improve our Services, and help recommend relevant offers or services.

Sources of Consumer Health Data We Collect: We collect Consumer Health Data from various sources, which include: from you; collected automatically; from third party services; personal information we create and infer.

Categories of Consumer Health Data We Share: We may share the following categories of Consumer Health Data with third parties and specific affiliates:

Precise location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies;
Data that identifies a consumer seeking “health care services” as defined under Washington’s My Health My Data Act, also referred to as “Identity Data;”
Any information that we or our respective processor, processes to associate or identify you with data described above that is derived or extrapolated from non-health information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning), also referred to as “Inference Data.”

Categories of Third Parties with Whom We Share: We may share Consumer Health Data with the following categories of third-party recipients: Service Providers & Agents; Partners; Data Aggregators; Legal Disclosure.

Specific Affiliates with Whom We Share: We do not currently share Consumer Health Data with specific Affiliates.

My Health My Data Rights:

Your Rights:

Under the Washington State My Health My Data Act, Washington State residents and natural persons whose Consumer Health Data is collected in Washington may have the following rights, subject to verification, exceptions, and limitations:

Right to Confirm/Access/Know – Up to twice annually, you have the right to (a) confirm whether we are collecting, sharing, or selling your Consumer Health Data, and (b) access such data, including a list of all third parties and affiliates with whom we have shared or sold the consumer health data and an active email address or other online mechanism that you may use to contact these third parties. (Effective March 31, 2024)

Right to Delete – You have the right to request deletion of the Consumer Health Data held by us and our affiliates, processors, contractors, and other third parties.

Right to Withdraw Your Consent/Opt-Out – You may withdraw any consent you have provided at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you, such as location-based services, personalizing or making relevant certain types of advertising, or other services conditioned on your consent or choice not to opt-out.

Right to Non-Discrimination – You have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the My Health My Data Act.

How to Exercise Your Rights:

You may submit requests as follows: [email protected]

You may email us: [email protected]
You may call us at: (800) 789-4455. You will be directed to leave a voicemail where you will provide your email address, phone number or address, along with your request.
To limit the use and disclosure of Precise Location Data, update your preferences for location data using your device’s settings menu, or disable WiFi, Bluetooth, or other interfaces you use to interact with our Services

If you have any questions or wish to appeal any refusal to take action in response to a rights request (if the right of appeal is granted by your state), contact us at [email protected]. We will respond to any request to appeal within the period required by law.

For Questions, or to Report a Problem

If you have other questions, comments or concerns about our privacy practices, or if you wish to issue a request to exercise your rights where applicable by law, please call Privacy Customer Service at (877) 399-1130 or emailing us at [email protected].

Effective Date

This Notice was last updated and effective on December 3, 2024.