Privacy Policy


Effective Date: August 1, 2017





This Privacy Statement and Notice of Privacy Practices (“Privacy Policy”) sets forth the privacy practices of JJFA, Inc., a California nonprofit mutual benefit corporation (“JJFA”).  For the purpose of the following terms, references to “We”, “Us” and “Our” include JJFA and its affiliates, subsidiaries, agents, representatives, successors and assigns.  We are an independent association of franchisees (the “Franchisee Members”) in the Jimmy John’s system, which, together with certain vendor members (the “Allied Partner Members”), works to maximize the value and profitability of the Franchisee Members’  franchises (together with all other goals and objectives of the Association, and any and all related services JJFA provides, the “Services”).


This Privacy Policy is applicable to all data collection by JJFA and shall apply to all Franchisee Members, Allied Partner Members, all users of JJFA’s website, and any and all other individuals or entities from whom JJFA collects data (the foregoing being referred to collectively herein as “You” or “Your”).  Without limitation of the foregoing, this Privacy Policy applies to Your use of Our web site, Your use of any affiliated third party Web sites that may contain a link to this Privacy Policy, to any pages, facilities, services, or capabilities accessible on or by any top-level JJFA domain owned by Us or any subsite, subdomain, subdirectory, virtual site, or virtual directory thereof (each, a “Site” and collectively the “Sites”), and the Services.  Additionally, this Privacy Policy will apply to any and all communications received or sent between You and JJFA.


This Privacy Policy shall apply strictly to information collected in the United States.  This Privacy Policy describes how JJFA treats Your use of the Sites, including the collection, storage, transfer, sharing, disclosure and handling of Your  information and Your use of Our Services. Additionally, this Privacy Policy describes how JJFA may treat any and all information collected through communications between JJFA and You.


By using or participating in Our Services or communicating with Us, You acknowledge that You have read this Privacy Policy and consent to JJFA’s privacy practices as described herein, including Our use and disclosure of Your information for the purposes described below.


We take the privacy of Your  information seriously.  If You have any questions or concerns about this Privacy Policy or Your  information please contact Us directly at the email or mailing address listed in Section 2 (Contact and Electronic Communication).


  1. Changes and Updates to this Privacy Policy


JJFA reserves the right to revise or update this Privacy Policy at any time within our sole discretion, and unless you discontinue Your use of or Our Site and Services You agree to be bound by those revisions or updates.  JJFA will notify You of any changes, revisions or updates to the Privacy Policy through any of the following methods (1) posting the revised or updated Privacy Policy and its “Effective” date on the Sites at least thirty (30) days prior to the change taking effect (2) including a copy of the revised or updated Privacy Policy and its “Effective” date in a notice accompanying the payment of membership dues (3) notification of the revised or updated Privacy Policy and its “Effective” date in an email to the email address as provided by You under Section 3.2 herein.  Your use of the Sites and Our Services thereafter constitutes Your agreement to and acceptance of this Privacy Policy and its revisions or updates.  You should periodically read the Privacy Policy to learn of any revisions or updates.  This Privacy Policy is incorporated as part of the General Terms of Use (which can be found linked on the home page of that apply with respect to Your use of the Sites and Our Services, which We define below in this Privacy Policy.  If You do not agree to the terms and conditions of this Privacy Policy, including having Your  information used in any of the ways described in this Privacy Policy, do not provide Us with Your information or use the Sites or Services.


  1. Contact and Electronic Communication


By using Our Services or providing Your  information to Us, You agree that We can communicate with You electronically regarding any legal, regulatory, technical, security, privacy and any administrative or consumer notification obligations that may be related to Your use of the Services. By using the Services and providing your contact information, to Us you agree that We may contact You by sending text messages to Your mobile telephone, sending e-mails to Your e-mail address and sending mail to Your address to inform You about and provide the Services. If You have any questions about this Privacy Policy or about Our Services related to the Privacy Policy, You can contact JJFA by e-mail at


You may also contact Us at:


JJFA, Inc.

Attn: Andy Markle, Executive Director

125 East High Street

Jefferson City, MO 65101


  1. Types of Information Collected and How it is Collected


3.1       Disclaimers.  The types of information We collect from You when You access Our Sites or use Our Services listed below which are not all-inclusive and other uses of information may be necessary to provide Our Services to You.  JJFA may share both Your Information with its affiliates, subsidiaries, partners and other third parties, such as third parties who help operate the Sites and related databases and Our mobile applications.  Use of such third parties is subject to the terms of use and privacy policies of those third parties.  JJFA is not responsible for the privacy practices of any other websites or third parties.  You should review the terms of use and privacy policies that are posted or provided by those third parties, before using any services they provide.  JJFA accepts no liability for any information, products, advertisements, content, services or software accessible through these third party websites or for any action You may take as a result of linking to any such website.  We collect information directly from You, through Your use of Our Sites, mobile applications, or Services or from third parties that work with JJFA to deliver Our Services.


3.2       Information We Request From You; Use of Information. Certain areas of the Sites (e.g. creating a user account) will require You to provide certain information about You, including without limitation You, or Your company’s name, phone number, e-mail address, mailing address, zip code, credit card information, bank account information, and other business information as necessary.  While it is Your choice whether to provide the requested information or not, We cannot provide certain Services You request if You do not provide the requested information.  By submitting this  information to JJFA, You agree that JJFA may use the information in accordance with this Privacy Policy, for example to provide You with the Services, adapt and improve JJFA services to better suit Your needs, provide benefits entitled to You, and to meet regulatory or contractual requirements relating to the services provided to You.  If You do submit such  information to JJFA, JJFA may share that information with third parties, in addition to using that information for the purposes for which it was submitted by You and for any other reasonably necessary purpose to provide You with the Services.


JJFA may also use this information in other ways, such as to provide You with information about Services and offers that may be of interest to You, to seek follow-up from You about Your experiences with JJFA or as otherwise disclosed to You.  Where required, JJFA will seek Your express consent to send such messages, including when sent by e-mail or other type of commercial electronic message.  You may withdraw Your consent by using the “unsubscribe” link located at the bottom of such e-mail messages You receive from JJFA, or alternatively, by contacting JJFA at the email or postal address listed in Your membership account.


Your Data, including without limitation, individual records, may at times be viewed or accessed for the purpose of resolving a problem, support issue, or suspected violation of the User Agreement.


JJFA may share Your  information with its affiliates, subsidiaries and partners and with other third parties.  Additionally, to the extent required by applicable federal or state law, JJFA may be required to disclose Your information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  By submitting information to JJFA, You give JJFA permission to receive it, review it, edit it, store it and use it for the purposes described in this Privacy Policy and for any other reasonably necessary purpose to provide You with the Services.


3.3       Other Information.  JJFA also may gather certain information about Your preferences, how You use Services, the use of JJFA’s Sites, including the number of unique visitors, the frequency of visits, how users interact with the Sites, user experience preferences, IP address, and other information that may help JJFA improve the member experience, mitigate fraudulent activity, and comply with legal requirements.  Such information may include, but is not limited to, the following:


3.3.1    Log Information.  When You visit JJFA’s Web sites We may automatically collect and store certain information in Our server logs.  This type of information includes details of how You interacted with Our Sites, Services, or applications.  It may include information such as: IP address, Unique Device Identifier, or CallerID / ANI (Automatic Number Identification) information, content of Web pages, transaction with APIs (Application Program Interface), transactions with IVR (Interactive Voice Response) systems, activity and content of visitor interaction with call center representatives, application usage activity, hardware information, hardware and system settings, browser type, browser language, the date and time of Your request, referral URL, etc.


3.3.2    Automatic Collection.  JJFA and its partners may use cookies or similar technologies to analyze trends, administer JJFA’s Sites, track users’ movements around the Site, and to gather demographic information about Our user base as a whole.


3.3.3    Cookies. A cookie is a small, data file that is managed by Your Web browser or other application and stored on Your local system.  JJFA may utilize session and persistent cookies to, among other things, identify Your computer during a particular interaction and analyze Your behavior during a particular visit.  Most Web browsers provide You with the ability to accept or decline cookies, as well as to be warned each time a cookie is being sent.  If You choose to decline cookies, You may not be able to fully utilize JJFA’s Sites, Services, or applications.


3.3.4    Pixel Tags. Pixel tags, also known as Web beacons, may help JJFA better manage user experience and content tracking.  Pixel tags are tiny graphics with a unique identifier, which provide a similar function to cookies and are used to track user interaction with content provided by JJFA or an affiliate organization.  In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded invisibly within content.  The small size and transparency of pixel tags are not intended to deceive content recipients, but minimize distraction.


3.3.5    Third Party Data Sources.  JJFA may leverage external data sources in order to provide context and background on the users of its Sites, Services, or mobile applications in order to improve customer experience, mitigate fraud or malicious activity, or comply with internal company and external regulatory requirements.


3.3.6    Do Not Track and Third Party Advertising Cookies.  Do-Not-Track is a public-private initiative,, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify Web sites that they do not wish to be “tracked” by third parties as defined by the initiative.  The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take.  As a result, Do-Not-Track has not yet been standardized and most Web sites, including JJFA Sites, do not alter their behavior or change their services when they receive a “do-not-track” flag or signal.  You can, however, make decisions about Your privacy and the advertisements You receive.


3.3.7    Interest-based Advertising.  Some of the ads You receive on Sites may be customized based on predictions about Your interests generated from Your visits to different Sites.  This type of ad customization is sometimes called “online behavioral” or “interest-based” advertising.  We may partner with a third party to manage Our advertising on other sites.  Our third party partner may use cookies or similar technologies in order to provide You advertising based upon Your browsing activities and interests.  If You wish to opt out of interest-based advertising You must notify Us via the contact information provided in Section 2.  Please note You may continue to receive generic ads. As an alternative to the opt-out, You can also elect to block all cookies from first parties (such as JJFA) and from third parties (such as entities involved in advertising) by using the cookie blocking options built into Your browser software.  Please note, however, that if You do decide to block cookies, some parts of JJFA’s Sites may not function correctly.


  1. Retention and Deletion of Information


JJFA will retain Your  information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and Your consent to such purposes(s) remains valid with respect to claims data and to file claims related to insurance coverage after termination of JJFA’s relationship with You.  When  information is no longer needed or legally required, it will be permanently deleted or de-identified so that it can no longer be associated with a specific individual.


  1. Use of Information


In addition to any of the previously mentioned uses of information, JJFA may also use Your information collected on the Sites for such purposes as: (a) helping to establish and verify Your identity; (b) activating and maintaining Your account; (c) for tax purposes; (d) contacting You to offer Service updates and notices, promotional notices and other information about Services or other services available from JJFA or its affiliates; (e) providing You with Services You have requested or authorized; (f) responding to Your questions, inquiries, comments and instructions; (g) improving the Sites by solving technical problems, calculating overall usage statistics, internal marketing and promotional purposes, Service development and content improvement; (g) taking good faith steps to enforce terms and conditions; and (h) maintaining the security and integrity of the Sites and JJFA’s systems.


  1. Sharing and Disclosure of Information


6.1       Generally.  Primarily, and without limitation of the generality of any other provision hereof, We may share or disclose Your information in the following instances:










6.2       Legal Disclosure.  We may disclose information about You and Your use of the services if We believe that such disclosure is reasonably necessary to: (i) comply with the law and/or legal process where a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding); (ii) protect or defend Our rights and/or property or the rights and property of others; (iii) enforce Our General Terms of Use and/or this Privacy Policy; and (iv) respond to claims that the content(s) of a communication violates the rights of another.  Also, circumstances may arise where, for business reasons, We may decide to reorganize, or divest all or part of Our business through sale, assignment, merger, acquisition, bankruptcy proceedings, or We may acquire a new business.  In these circumstances,  information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business.


  1. People Under the Age of 18


The Services provided by JJFA are not directed or available to persons under eighteen (18) years of age.  If You become aware that Your child, who is under eighteen (18) years of age, is accessing the Services and providing information without Your consent, please contact Us by using the information provided in the Contact and Electronic Communication section of this Privacy Policy.  JJFA will take steps to remove the child’s  information from JJFA’s data collection systems and terminate Your child’s account should JJFA determine that a child under eighteen (18) has accessed the Services.


  1. Security of Information


Information submitted via the Internet, including through a web page, mobile application, or e-mail is subject to interception or incorrect routing, and the Internet is not a fully secure communications channel.  Please consider this prior to submitting any information to JJFA via the Sites or a mobile application.  While JJFA follows generally accepted industry standards to protect the information submitted to Us, no method of transmission over the Internet, or method of electronic storage, is completely secure.  Therefore, while JJFA strives to use commercially acceptable means to protect Your information, JJFA cannot guarantee its absolute security.  For information specific to credit card processing and data security please review these specific sections under this Privacy Policy.


  1. Credit Card Processing and Data Security


JJFA does not receive or distribute funds directly from or to You when You utilize the Sites or the Services.  JJFA utilizes a third party billing and payment processing gateway, provided by or more third party payment administrators (collectively, the “Payment Administrator”) who provides the infrastructure and security necessary to provide secure transmission of Your credit card transaction data. Payment Administrator, whose identity(ies) JJFA will disclose upon request can provide You with its terms of service  and privacy policy.  JJFA can only accept credit cards for processing through Our secured payment processing gateway.  Although We do not control the security environment for them and cannot make any guarantees regarding the secure processing of Your credit card transaction data, We want to inform You that to our knowledge Our credit card processor is compliant with the applicable Payment Card Industry Data Security Standard (“PCI DSS”).  We demand that Our credit card processors are compliant with PCI DSS.  PCI DSS is the bankcard industry’s most stringent security standard.


  1. Social Media


Any information, communications, or material of any type or nature that You submit to the Sites or through JJFA’s Services (including, but not limited to any JJFA Sites contained on a social media platform or web site such as Facebook, Instagram or Twitter) by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at Your own risk and without any expectation of privacy.  JJFA cannot control the actions of other users of any social media platform or web site and JJFA is therefore not responsible for any content or Submissions contained on such sites and platforms, irrespective whether the subpage or user page on a social media website is organized by JJFA or anyone affiliated with it.  By visiting any JJFA Site that is contained on a social media platform or Web site, You are representing and warranting to JJFA that You have reviewed the applicable privacy policy and terms of use of such platform or web site and that You will abide by all such provisions contained therein.  Additionally, in the event that JJFA offers a message board or any other interactive or social-type feature on the Sites, please be aware that these areas may allow You to publicly post, and share with other users, certain messages, content, or other information (e.g., stories, pictures, tips, etc.).  Although JJFA may take certain precautions to protect those who use these areas of the Sites, JJFA encourages You to be wary of providing any of Your  information in such public forums.  The information You submit can be collected and used by people You do not know.  JJFA does not in any way guarantee the privacy and safety of these areas and is therefore not responsible for any information You choose to submit.  Your use of these features is fully at Your own risk.


  1. International Users


If You are visiting from the European Union or other regions with laws governing data collection and use that may differ from United States law, please note that You are transferring information about You, including  information, to a country and jurisdiction that does not have the same data protection laws as the European Union, and You consent to the transfer of information about You, including Your  information, to the United States, and to the use and disclosure of information about You, including Your  information, as described in this Privacy Policy.


  1. Monitoring and Enforcement


JJFA has implemented various measures to monitor compliance with and enforce the elements in this Privacy Policy.  If You have a privacy related inquiry, complaint or dispute, please contact Us at the postal or e-mail listed in the Contact and Electronic Communication section of this Privacy Policy.



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