Cut Time® Privacy Policy

This Privacy Policy provides Users of Cut Time® with important information about the privacy practices used at the http://cuttime.net/ website and all associated webpages (the “Cut Time Site”) and all other products, services and applications made available through and in conjunction with the Cut Time Site from time to time (the “Services”) which are furnished by J.W. Pepper & Son, Inc. ("J.W. Pepper,” “we” or “us”).  

The Cut Time Site and Services are intended to be used by subscribing organizations (“Subscriber(s)”) to assist in the management of music programs and other multi-member programs (“Programs”) by facilitating communication by and between those organizing and managing the Programs (“Program Administrator(s)”), the staff and personnel associated with the Programs (“Staff”) and the members of the Programs (“Members”) and to manage the schedules, equipment and other items used by Members and Staff of the Programs.   This Privacy Policy relates primarily to information (“Covered Information”) of Members and other Users (“Users” or “you”) on the Cut Time Site and/or included in the Services.

This Privacy Policy, together with our Terms of Service (“Terms of Service”),  govern J.W. Pepper’s relationship with Users in relation to the Cut Time Site and Services, describe the information we collect from or about Users in the Cut Time Site and Services, set out how we use and share that information and outline some of the steps we take to protect the privacy of Users. 

Covered Information may be posted to the Cut Time Site and Services by a number of different contributors. These include the Subscribers, Program Administrators, Staff as well as the Users themselves.   Restrictions on the types of information that may be posted are set forth in the Terms of Service.

Covered Information may include Personally Identifying Information as well as Covered Information which is subject to the Family Education Rights and Privacy Act (“FERPA”)  that regulates “Student Data”, and the Children’s Online Privacy and Protection Act (“COPPA”) that governs the collection, use and disclosure of personal information collected from children under age 13.  The Cut Time Site and Services are designed and implemented to satisfy FERPA and COPPA and other federal, state and local laws concerning the gathering and use of personal information.          

Gathering of Personally-Identifying Information (Generally)

J.W. PEPPER DOES NOT RENT OR SELL PERSONALLY-IDENTIFYING INFORMATION TO THIRD PARTIES BUT MAY USE SUCH INFORMATION TO IMPROVE AND PROMOTE THE CUT TIME SITE AND SERVICES TO USERS.

Some Users to the Cut Time Site and Services may choose to interact with the Cut Time Site and Services in ways that may require them to provide personally-identifying information (“PII”).  For example, a User may submit PII to the Cut Time Site and Service by registering a User profile at the Cut Time Site.  PII may also be provided to us by schools and other educational institutions that are Subscribers or by their Program Administrators or Staff. [See, “Special Provisions Regarding Student Data” and “Children’s Privacy – ‘COPPA’ Notice.”] PII generally refers to a person’s name, address, telephone number, email address, credit card information, government‑issued identity information (such as a driver’s license or social security card), and any other data that may be used to identify or contact such person.  The amount and type of PII that the Cut Time Site and Service gathers depends on the nature of the interaction chosen by the User.  It may also include information regarding a person’s health or disabilities. J.W. Pepper does not disclose PII other than as described below and then, subject to all legal restrictions.  Users may always refuse to supply PII but that may prevent them from fully engaging in certain website-related activities.

J.W. Pepper discloses PII only to those employees and its contractors who use that information in order to process or perform essential business functions on J.W. Pepper’s behalf or to provide services available on the Cut Time Site and Services.   If a User (or a Subcriber, Program Administrator or Staff) of the Cut Time Site and Services have supplied your email address, we may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with the Cut Time Site as well as other J.W. Pepper products. 

Gathering of Non-Personally Identifying Information

Like most websites, the Cut Time Site and Services also collects non-personally-identifying information of the sort that web browsers and servers typically collect regarding Users’ visits to the Cut Time Site and Services, such as the browser type, language preference, referring site, and the date and time of each User request. Our purpose in collecting this information is to better understand how Users of the Cut Time Site and Services use the service. We reserve the right to use non-personally-identifying information data for any other lawful purpose, including the development of aggregated statistics.  The Cut Time Site and Services may also collect statistics about the behavior of Users on its websites. For instance, we may gather membership statistics, network visits, etc.

Special Provisions Regarding Student Data (FERPA)

FERPA imposes certain restrictions on the use of “Student Data” of students under age 18.

While J.W. Pepper does not purposely collect PII from students, the Cut Time Site may be used by schools and other educational institutions and, as a consequence of such use, by the students themselves.  In providing services to their Users, and, as a consequence, the Cut Time Site and Services may obtain a type of PII regarding those students (“Student Data”).  “Student Data” is any information (in any format) that is directly related to an identifiable current or former student that is maintained by a school, school district, or related entity or organization, or by us, as part of the provision of the services to such entity or organization. Student Data may include “educational records” as defined by the Family Educational Rights and Privacy Act (“FERPA”).  FERPA classifies Student Data as “educational information,” “personally-identifiable information” and “directory information” and requires different levels of protection regarding each. For example, directory information – a student’s name, address, telephone number, date and place of birth, honors and awards, sports and activities and dates of attendance – are unprotected and may be disclosed.  What is called “de-identified data – data without any PII -- may also be freely used.

Under FERPA, students who are Users (and, in some cases, their parents and legal guardians) may access their Student Data on the Cut Time Site and Services and, upon their request, have some or all of such Student Data modified or deleted.

J.W. Pepper considers Student Data to be strictly confidential, and we do not use such data for any purpose other than providing and improving the Cut Time Site and Services, to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with the Cut Time Site and Services as well as other J.W. Pepper products. 

 We agree that students who are Users (or, in some cases, their parents or legal guardians) may access their Student Data (except for directory information and de-identified data) on the Cut Time Site and Services and, upon their request, have some or all of such Student Data corrected, modified or deleted. We agree not to share Student Data (except for directory information and de-identified data) with third parties other than the Subscribers, Program Administrators, Staff and other Users in the Program, without the student’s consent.  Our collection, use and sharing of Student Data may also be governed by applicable city, state and federal laws, as well as by the provisions contained in this Privacy Policy, including, by the restrictions set forth in “Children’s Privacy – COPPA Notice” which follows. 

If you believe we may have inadvertently posted Student Data without proper consent or authorization or you want it deleted for other reasons, please contact us by email at [email protected], and we will delete such information immediately.

 

Children’s Privacy – “COPPA” NOTICE

NOTICE TO PARENTS OF CHILDREN UNDER THE AGE OF 13

J.W. PEPPER OWNS AND OPERATES THE CUT TIME SITE AND SERVICES TO PROVIDE AN ONLINE SERVICE TO MUSIC PROGRAMS AND OTHER MULTI-MEMBER ORGANIZATIONS AND MAY COLLECT PERSONALLY-IDENTIFYING INFORMATION (“PII”) FOR USES CONSISTENT WITH THAT PURPOSE.   PURSUANT TO THE CHILDREN’S ONLINE PROTECTION ACT, J.W. PEPPER HAS ADOPTED POLICIES POSTED HERE TO PROTECT THE PII OF CHILDREN UNDER THE AGE OF 13, WHICH POLICIES REQUIRE YOUR VERIFIABLE CONSENT TO USE, ADD, MODIFY OR DELETE PII ON THE CUT TIME SITE, AS WELL AS THE WAY TO FILE COMPLAINTS WITH J.W. PEPPER RELATED TO THOSE POLICIES.     

In 1998, Congress enacted the Children’s Online Protection Act (15 U.S.C. § 6501 – 6506) which has become known as “COPPA.”  COPPA strictly limits the collection and use of the PII of children under the age of thirteen (13) years (“COPPA Users”) and gives their parents or legal guardians (“COPPA Parents”) control over the use of such PII.  J.W. Pepper has adopted the following policies to comply with COPPA. 

While J.W. Pepper does not purposely collect PII from children under the age of thirteen (13) years, the Cut Time Site and Services may be used by schools and other educational institutions that are Subscribers.  In providing the Cut Time Site and Services to their Users, and, as a consequence of such use, the Cut Time Site and Services may obtain PII regarding COPPA Users.  J.W. Pepper must rely upon the Subscribers and Program Administrators to identify COPPA Users. Upon receipt of PII from a User that a Subscriber or Program Administrator has identified as a COPPA User, will verify that the COPPA Parents have consented to the use of the COPPA User’s PII on the Cut Time Site and Services. The Subscriber will also be asked to provide J.W. Pepper with contact information (including an e-mail address) for the COPPA Parents.  Thereafter, and so long as the User is a COPPA User, the COPPA parent may access the PII of his or her COPPA User and  PII regarding the COPPA User may be added, modified or deleted, in whole or part, only by the COPPA Parents or with the verifiable consent of the COPPA Parents (which may be obtained by e-mail). At such time as the COPPA User’s age exceeds thirteen (13) years, such User shall succeed to the rights of the COPPA Parents. 

J.W. Pepper reserves the right to use de-identified data that is derived from PII of COPPA Users to improve the Cut Time Site and Services.  J.W. Pepper also reserves the right to contact COPPA Parents to verify their consent, tell them about new features, solicit their feedback, or just keep them up to date with what’s going on with the Cut Time Site and Services as well as other J.W. Pepper products. 

If you believe we may have inadvertently posted PII of a child under the age of thirteen years without proper consent and authorization, please contact us by email at [email protected], and we will delete such information immediately.

Cookies

A cookie is a small text file containing a string of information that a website, online application, or email stores on a User’s computer, and that the User’s browser provides to the website to allow the website to recognize a specific User each time the User returns. The Cut Time Site and Services uses cookies to help identify and track Users, their usage of the Cut Time Site and Services, and their website access preferences. 

Users of the Cut Time Site and Services can choose to accept or decline cookies on their computers. Most web browsers automatically accept cookies, but you may be able to modify your browser setting to decline cookies if you prefer. The “help” portion of the toolbar on most browsers may tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies, or how to disable cookies altogether. If you disable or reject cookies, this may prevent you from taking full advantage of the Cut Time Site and Services, as certain features may not function properly without the aid of cookies.

Disclosure and Sharing of Information We Gather

Notwithstanding anything else in this Privacy Policy, we may disclose any information as may be required by applicable law, regulation or legal process, such as a subpoena.  Additionally, we may disclose any information to law enforcement and other parties when we believe it is appropriate in order to investigate or protect against actual or suspected illegal, criminal or fraudulent activity, hacking, violations of our terms of use, contravention of the security features of our site, or any activity that we believe may pose a risk to the rights or security of us, our business, our employees, our property or the Users of the Cut Time Site and Services.

User Generated Content

If Users elect to post content on the Cut Time Site and Services or submit content to us directly, any information, including, without limitation, your name, address, e-mail address, interests and ideas may be stored and used for research or other promotional purposes by us.  We may contact you directly to discuss your use of, or contributions to, the Cut Time Site and Services. If you offer a testimonial or opinion about products and services on the Cut Time Site and Services, you authorize us to use these communications in our marketing campaigns, on and off the Site.  We may include in our marketing campaigns your initials, or your first name and the first letter of your last name, together with the name of the city/locality and state where you reside.

Users of the Cut Time Site and Services may elect to post content to a specific organization’s Cut Time Program.  The Program Administrator(s) managing such Program shall determine what content and data is collected and shared among members of the organization by granting permissions or restricting access to Members of the organization.  We expressly disclaim any liability or responsibility for matters relating to privacy, security and other matters on any websites other than the standard web pages on the Cut Time Site and Services. We strongly advise you to review the terms of use and privacy and other policies of any other website that you visit including websites that may be linked to the Cut Time Site and Services.

Your Choices Regarding Your Information

At any time, Users may access, update and delete the information listed in their Cut Time dashboard profiles.  

Program Administrators managing a Cut Time Program may assign permissions and limit roles to specific Users within an organization.   Subscribers may terminate an organization’s Cut Time subscription at any time. Terminating a subscription will result in the deletion of all records any User has created in the organization’s account and all information contained within the records. You agree not to use the Cut Time Site and Services as the sole repository for any information.

If at any time, you no longer wish to receive email messages from us, let us know by clicking the “Unsubscribe” option in any of our emails or notify us by email to [email protected].   If you would like to have your PII edited or removed from our records, you may request a revision or deletion by contacting us by email at [email protected]. If you believe that any information we are holding relating to you is incorrect or incomplete, you may request a correction by contacting us by email us at [email protected] as soon as possible. We will promptly correct any information found to be incorrect.

Security

In addition to J.W. Pepper employees and contractors, only authorized Users with registered passwords will have access to the information in your members-only dashboard.  Your Cut Time account data is backed up on redundant servers and off-site data storage.   Should you experience technical problems, our authorized technical support staff may need to access your account to assist you.  

We have implemented commercially reasonable technical and organizational measures on the Cut Time Site and Services designed to secure PII, User content and associated data collected at the Cut Time Site and Services from accidental loss and from unauthorized access, use, alteration or disclosure. We cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your User content or associated data for improper purposes, and you acknowledge that all User content and associated data is provided on Cut Time at your own risk. J.W. Pepper disclaims any warranty or representation relating to maintenance, data security, or nondisclosure of data.

“Phishing” is a scam designed to steal your personal information. If you receive an email that looks like it might be from J.W. Pepper asking for your personal information, do not respond.  We do not request your password, User name, credit card information, or other personal information through email.

Privacy Policy Changes

J.W. Pepper reserves the right to change its Privacy Policy from time to time, in its sole discretion. If we do so, we will notify you of substantial changes to this Privacy Policy either by posting our updated privacy policy on the Cut Time Site, together with the effective date of the updated policy and/or by sending a message to the e-mail address you have provided to us. Users are required to check this page periodically for any changes to our Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of all such changes.

Your Concerns about Privacy may be addressed as follows:

If you have any questions or comments about the Privacy Policy or your interactions with the Cut Time Site and Services, please contact us: 

Email us at: [email protected] 

Call our customer service number at: 1-800-310-0087

Send us regular mail at:          J.W. Pepper & Son, Inc.

                                                191 Sheree Blvd.

Exton, PA 19341

 

Notice to Users Who are California Residents 

The California Consumer Privacy Act

If You are a California resident please read the information in this section. The State of California has enacted the California Consumer Privacy Act of 2018 (“CCPA”) and it may give Users (“You” or “Your”) additional rights respecting Your “Personal Information.” The term “Personal Information” and many other terms used in this section are defined in the CCPA and You may wish to consult the CCPA in order to better understand Your rights under this section. It is codified in the California Civil Code in Sections 1798.100 to 1798.199. 

Categories of Personal Information which J.W. Pepper may have collected from or about You in the preceding 12 months:

  • Your identifying information (for example, Your name, mailing address, e-mail address, phone number, credit/debit card number) 
  • Characteristics of Your protected classifications (for example, Your gender and age) 
  • Commercial information (for example, the products and services You purchased and Your purchase history) 
  • Internet or other electronic network activity (for example, Your browser or search history) 
  • Geolocation data about You (for example, latitude or longitude) 
  • Audio, electronic, visual, or similar information (for example, recordings of Your calls to J.W. Pepper for information or assistance) 
  • Inferences about You which J.W. Pepper may draw from any or all of the above (for example, Your preferences or characteristics of Your decision making) 

Categories of sources from whom J.W. Pepper may have collected Personal Information about You: 

  • J.W. Pepper’s online and brick-and-mortar stores 
  • www.jwpepper.com or affiliated websites   
  • e-mails that You sent to J.W. Pepper
  • J.W. Pepper’s mobile applications 
  • customer relations experiences 
  • Your credit applications or credit history and ratings 
  • other websites that You visit 
  • data brokers  
  • social media 

Business or commercial purposes for which J.W. Pepper may have collected or sold Personal Information about You in the preceding 12 months: 

  • to maintain or service Your accounts;
  • to provide You with customer service and process or fulfill Your orders and transactions;
  • to verify Your customer information and process Your payments; 
  • to provide advertising or marketing services, process analytics services, or perform similar services; 
  • to audit and improve J.W. Pepper’s interaction with You and other Customers and to document website and in-person delivery of services and products and information regarding both;
  • to count ad impressions by unique visitors and to verify positioning and quality of ad impressions; 
  • to customize advertising to make it more inviting to You and other customers; 
  • to establish, operate and improve one or more loyalty programs;
  • to detect failures in security and data breaches and to protect against malicious, deceptive, fraudulent, or illegal activity, and to aid in prosecuting those responsible for such activity; 
  • to debug and to identify and repair errors that impair functionality of J.W. Pepper’s websites; 
  • to train and re-train J.W. Pepper’s personnel to better serve You and other customers;
  • to establish, maintain and improve J.W. Pepper’s relationships with its partners and suppliers and to address problems that You identified with their products and services
  • to undertake customer, product and technology research; and 
  • to identify, test and better market products and services to be offered by J.W. Pepper

 

Categories of Personal Information J.W. Pepper may have sold about You in the preceding 12 months

 

  • Identifiers (for example, name, mailing address, email address, phone number, credit/debit card number) 
  • Characteristics of protected classifications (for example, gender, age) 
  • Commercial information (for example, products or services purchased, purchase history) 

 

  • Internet or other electronic network activity (for example, “cookies” or other tracking tags)
  • Personal Information needed by J.W. Pepper’s business partners and suppliers to accept, process and fulfill orders that You placed with J.W. Pepper 

Categories of Personal Information J.W. Pepper may have disclosed for a business purpose in the preceding 12 months

  • Identifiers (for example, name, mailing address, email address, phone number, credit/debit card number) 
  • Characteristics of protected classifications (for example, gender, age) 
  • Commercial information (for example, products or services purchased, purchase history) 
  • Internet or other electronic network activity (for example, browse or search history)
  • Personal Information needed by J.W. Pepper’s business partners and suppliers to accept, process and fulfill orders that You placed with J.W. Pepper

 

Non-Discrimination

J.W. Pepper will not discriminate against You because You exercise Your rights under the CCPA or other applicable law. For example, J.W. Pepper will not deny You goods or services or charge You a different price or rate for goods or services if You make an access, deletion, or do not sell request. 

Promotions and Loyalty Programs 

J.W. Pepper may, from time to time, establish promotions or loyalty programs which require You to consent to J.W. Pepper’s use of Your Personal Information in order to join or participate in such promotions or loyalty programs. Your participation will always be voluntary and You may cancel Your participation or “opt out” at any time over the telephone or by e-mail using the contact information listed below. If You cancel or opt out of any such promotion or program, Your Personal Information will be deleted and You may not have access to the promotions or programs.

You have the following rights under the CCPA:

The right to make requests as follows: 

Access Request (You can make such a request no more than twice in any 12-month period and Request that J.W. Pepper disclose the following information)

- Categories of Personal Information we collected about You during the preceding 12 months 

- Categories of sources from which Personal Information is collected about You 

- Business or commercial purpose for collecting or selling Personal Information 

- Specific pieces of Personal Information we collected about You 

- Categories of Personal Information about You that J.W. Pepper has sold 

- Categories of third parties to whom the Personal Information was sold 

- Categories of Personal Information disclosed about You for a business purpose 

- Categories of third parties to whom Personal Information was disclosed for a business purpose 

 

Deletion Request

- Request J.W. Pepper delete Personal Information that we collected about You 

Do Not Sell My Info

- Request J.W. Pepper opt You out of the sale of Your Personal Information 

Exercise Your rights under the CCPA as follows:

Access Requests

You can email [email protected] or call 1-800-310-0087

Deletion Requests

You can email [email protected] or call 1-800-310-0087

Do Not Sell My Info Requests 

You can email [email protected] or call 1-800-310-0087

            All Other Inquiries

You can email [email protected] or call 1-800-310-0087

 

 

California Shine the Light Law

If You are a California resident and have an established business relationship with J.W. Pepper, You can also request a report disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year under California’s "Shine the Light" law (California Civil Code Section 1798.83). 

If You are a California resident under 18 years old and a registered user with J.W. Pepper, You can request that J.W. Pepper remove content or information that You have posted to a J.W. Pepper website or other online service.  Note that the requested deletion may not ensure complete or comprehensive removal (for example, if the content or information has been reposted by another user).  

Exercise Your rights under the CA Shine the Light Law as follows:

Report Requests

You can email [email protected] or call 1-800-310-0087

Deletion Requests

You can email [email protected] or call 1-800-310-0087

            All Other Inquiries

 

You can email [email protected] or call 1-800-310-0087

Notice to Users Who are California Students or Their Parents

If You are a California student under the age of 18, or the parent of such a student, You also have rights arising under the California Student Online Personal Information Protection Act or “SOPIPA” (California Business and Professions Code §§22584 -22585) and, if Your school or school district (“Local Educational Institution” or “LEA”) has entered into a California Student Data Privacy Agreement (“DPA”) with J.W. Pepper for Cut Time, under the DPA, both of which protect “Pupil Records” (information contributed by the LEA) and “Pupil-generated content” (information contributed by the student), collectively, “Student Data.”

Generally, SOPIPA and any applicable DPA, which implements SOPIPA and provisions of the California Education Code relating to Pupil Records (including §49073), governs the collection and permitted access, use and disclosure of Student Data stored in Cut Time as well as the security procedures to be employed by J.W. Pepper, the training of its employees in those procedures and the steps which J.W. Pepper must take in the event of a “Data Breach” or other unauthorized disclosure.

Specifically, SOPIPA and any applicable DPA, prohibit J.W. Pepper from using Student Data to; (i) engage in targeted advertising; (ii) use Student Data except as required to deliver (or improve) Cut Time; (iii) create student identifiers and profiles for use other than in connection with Cut Time; (iv) sell Student Data; (v) disclose or give access to Student Data except to the LEA. They also require J.W. Pepper to direct parents (and others) who want access to Student Data to the LEA to gain access and request correction or deletion of Student Data and provide for correction and deletion of Student Data in certain circumstances.

An applicable DPA provides for the destruction of Pupil Records and the creation of separate accounts to store Pupil-generated content (severable from the overall Cut Time account) upon the termination of the DPA. It also provides procedures to be employed by J,W. Pepper in the event of a Data Breach. 

Exercise Your rights as a California Student or Parent as follows:

          To Access Student Data: Contact Your LEA (Local Education Agency)

            To Correct or Delete Student Data: Contact Your LEA (Local Education Agency)

For More Information Regarding Your LEA’s DPA: Contact Your LEA (Local Education Agency)

 

Notice to Users Who are Nevada Residents 

If You are a Nevada resident please read the information in this section. The State of Nevada has enacted several laws that may give You additional rights respecting Your “Personal Information” that is “Covered Information.” Note that “Covered Information” does not include Personal Information that is not collected online.

Categories of Personal Information which J.W. Pepper collects; “Covered Information”:

  • Your identifying information, including Your name, mailing address, e-mail address, phone number, credit/debit card number, social security number or other identifier or information, which, in combination, personally identifies You “Covered Information”   
  • Characteristics of Your protected classifications (for example, Your gender and age) 
  • Commercial information (for example, the products and services You purchased and Your purchase history) 
  • Internet or other electronic network activity (for example, Your browser or search history) 
  • Geolocation data about You (for example, latitude or longitude) 
  • Audio, electronic, visual, or similar information (for example, recordings of Your calls to J.W. Pepper for information or assistance) 
  • Inferences about You which J.W. Pepper may draw from any or all of the above (for example, Your preferences or characteristics of Your decision making) 

J.W. Pepper collects Personal Information about You, including Covered Informationfrom online and other sources, including: 

  • J.W. Pepper’s online and brick-and-mortar stores 
  • www.jwpepper.com or affiliated websites   
  • e-mails that You sent to J.W. Pepper
  • J.W. Pepper’s mobile applications 
  • customer relations experiences 
  • Your credit applications or credit history and ratings 
  • other websites that You visit 
  • data brokers  
  • social media 

J.W. Pepper shares Personal Information, including Covered Information, with Third Parties for business and commercial purposes, including the following: 

  • to maintain or service Your accounts;
  • to provide You with customer service and process or fulfill Your orders and transactions;
  • to verify Your customer information and process Your payments; 
  • to provide advertising or marketing services, process analytics services, or perform similar services; 
  • to audit and improve J.W. Pepper’s interaction with You and other Customers and to document website and in-person delivery of services and products and information regarding both;
  • to count ad impressions by unique visitors and to verify positioning and quality of ad impressions; 
  • to customize advertising to make it more inviting to You and other customers; 
  • to establish, operate and improve one or more loyalty programs;
  • to detect failures in security and data breaches and to protect against malicious, deceptive, fraudulent, or illegal activity, and to aid in prosecuting those responsible for such activity; 
  • to debug and to identify and repair errors that impair functionality of J.W. Pepper’s websites; 
  • to train and re-train J.W. Pepper’s personnel to better serve You and other customers;
  • to establish, maintain and improve J.W. Pepper’s relationships with its partners and suppliers and to address problems that You identified with their products and services;
  • to undertake customer, product and technology research; and 
  • to identify, test and better market products and services to be offered by J.W. Pepper.

 

You can review and change Your Covered Information online and by Written Request

 

  • If you have created an account on www.jwpepper.com, you can log in and go to My Account > My Profile > Update Profile on jwpepper.com to review and update your Personal Information, including contact, billing, and shipping information.
  • You may also request a report of Your Covered Information or request a correction to such Covered Information by sending a written request therefor to J.W. Pepper & Son, Inc., Attn: Nevada Privacy Inquiry, 191 Sheree Blvd., Exton, PA 19341. Please allow 60 days for a response.

You have the following rights under the Nevada Privacy Laws:

Correction Request

- Request J.W. Pepper report Covered Information that We collected from or about You and make proper corrections when requested. 

Do Not Sell My Info

- Request J.W. Pepper opt You out of the sale of Your Covered Information. 

 

 

Exercise Your rights under the Nevada Privacy Laws as follows: 

Correction Requests

You can email [email protected] or call 1-800-310-0087

Do Not Sell My Info Requests 

You can email [email protected] or call 1-800-310-0087

            All Other Inquiries

You can email [email protected] or call 1-800-310-0087

 

 

 

Notice to Users covered by the EU General Data Protection Regulation of 2018 

J.W. Pepper’s Services are provided, supported and hosted in the United States and intended for use by Users located in the United States. Use of the Services are governed by United States law, and United States privacy and data security laws may differ from those of other countries. If You use Services from outside of the United States, please be aware that any information that J.W. Pepper gathers under this Policy may be transferred to, stored and processed in the United States.  Notwithstanding the foregoing, J.W. Pepper provides the following to comply with the EU General Data Protection Regulation of 2018 (the “GDPR”).

Legal Basis for Processing Personal Data under GDPR

J.W. Pepper may process Your Personal Data under the following circumstances:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Your Rights under the GDPR:

J.W. Pepper undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights under the GDPR.

You have the right under this Privacy Policy, and by law if You are protected by the GDPR, to:

  • Request access to Your Personal Data. The right to access, update or delete the information J.W. Pepper has about You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If You are unable to perform these actions yourself, please contact J.W. Pepper (using the contact information below) to assist You. This will also enable You to receive a copy of the Personal Data J.W. Pepper possesses about You.
  • Request correction of the Personal Data that J.W. Pepper possesses about You. You have the right to have any incomplete or inaccurate information J.W. Pepper possesses about You corrected.
  • Object to processing of Your Personal Data. This right exists where J.W. Pepper are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where Pepper are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Pepper to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. Pepper will provide to You, or to a third-party that You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where Pepper used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent to using your Personal Data. If You withdraw Your consent, Pepper may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, correction, objection, erasure, transfer or withdrawal of Your consent by contacting Pepper (using the contact information below). Please note that Pepper may ask You to verify Your identity before responding to such requests. 

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Exercise Your rights under the GDPR as follows:

All Requests

Contact Pepper, in writing, at J.W. Pepper & Son, Inc., Attn: GDPR Privacy Inquiry, 191 Sheree Blvd., Exton, PA 19341

 

Notice to other Users from Outside the United States

The Cut Time Site and Services and Services are provided, supported and hosted in the United States and intended for use by Users located in the United States.  Use of the Cut Time Site and Services are governed by United States law, and United States privacy and data security laws may differ from those of other countries.  If you are using the Cut Time Site and Services from outside of the United States, please be aware that any information we gather under this Privacy Policy may be transferred to, stored and processed in the United States.

Other Related Policies

Fair Information Practices

 

Pepper will take the following responsive action, should a data breach occur:

Pepper will notify you via email within 7 business days and comply with all applicable laws and regulations regarding remediation.

 

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

Pepper collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions
  • Process orders and to send information and updates pertaining to orders
  • Send you additional information related to your product and/or service
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred


To be in accordance with CANSPAM, Pepper agree to the following:

  • Not use false or misleading subjects or email addresses
  • Identify the message as an advertisement in some reasonable way
  • Include the physical address of our business or site headquarters
  • Monitor third-party email marketing services for compliance, if one is used
  • Honor opt-out/unsubscribe requests quickly
  • Allow users to unsubscribe by using the link at the bottom of each email.


 If at any time you would like to unsubscribe from receiving future emails, 
follow the instructions at the bottom of each email to be promptly removed from ALL correspondence.

Policy last revised: April 2021