Last Updated and Effective: December 30,2019
Type of Data Collected
While using Our Services (website, blog, app) we may ask you to provide us with certain
personally identifiable information (PII) through direct web forms that can be used to
contact or identify you. We collect information from you when you register on our site to
make use of our services, place an order, subscribe to a newsletter, or respond to a survey.
PII may include, but is not limited to:
• Email address
• First and last name
• Phone number
• School, Church, or other organization name
• Mailing Address, State, Province, Zip/postal code, City
• Billing Address, State, Province, Zip/postal code, City
• Credit card information (JW Pepper does not store this data
• Usage data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up
for our newsletter, respond to a survey or marketing communication, browse the website, or
use certain other site features in the following ways:
• To personalize your experience with offering in which you are most interested
• To improve our website in order to better serve you
• To allow us to better service you in responding to your customer service requests
• To administer a contest, promotion, survey or other site feature
• To process your order
• To ask for ratings and reviews of services or products
• To follow up with you after correspondence (email or phone inquiries)
How do we store and protect your information?
Your personal information is stored in on-premise databases contained behind secured networks and is only accessible by a limited number of persons with special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information.
All credit card transactions are processed through a gateway provider and are not stored or processed on our servers.
How can you make changes to your information?
You may make changes to some of your Personal Information (name, email address, mailing and
billing addresses) online via My Account > My Profile > Update Profile on jwpepper.com. Any
additional relationship information, including your current place of employment and
position, please contact us directly:
• Phone: 1-800-345-6296
• Email: firstname.lastname@example.org
Do we use 'cookies'?
• Help remember and process the items in the shopping cart
• Understand and save user's preferences for future visits
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since every browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.
If users disable cookies in their browser:
If you turn cookies off it will turn off some of the features of the site.
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We do not include or offer third-party products or services on our website.
We have implemented the following:
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection Act (CalOPPA)
Users can visit our site anonymously.
You can change your personal information by:
• Visiting My Account > My Profile > Update Profile at jwpepper.com
• Calling 1-800-345-6296
• Email email@example.com
Do Not Track Signals
There is no accepted standard on how to respond to Do Not Track signals. JW Pepper takes privacy and security very seriously and strives to put our customers first in all aspects of our business. With regard to DNT, we do not respond to DNT signals in browsers because no standard has yet been adopted.
To learn more about DNT and how to control your browser's DNT settings, visit All About Do Not Track - https://allaboutdnt.com/
Children Online Privacy Protection Act (COPPA)
When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
• Consent: You have given Your consent for processing Personal Data for one or
• 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.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
JW Pepper undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
• Request access to Your Personal Data. The right to access, update or delete
information We have on 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 Us to assist You. This also enables
You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We 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 We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us 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. We will provide to You, or to a third-party 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 We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We 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, rectification, cancellation and opposition by contacting Us. Please note that we 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.
California Consumer Protection Act (CCPA)
Your Rights under the CCPA
• The right to notice. You must be properly notified which categories of
are being collected and the purposes for which the Personal Data is being used.
• The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
• The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section or web page.
• The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
• The categories of Personal Data collected
• The sources from which the Personal Data was collected
• The business or commercial purpose for collecting or selling the Personal Data
• Categories of third parties with whom We share Personal Data
• The specific pieces of Personal Data we collected about You
• The right to delete Personal Data. You also have the right to request
Your Personal Data that have been collected in the past 12 months.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to You
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email firstname.lastname@example.org, call us at 1-800-345-6296 or visit our Contact Us Form at https://www.jwpepper.com/sheet-music/services-contact.jsp.
The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
We will not discriminate against you for exercising any of your CCPA rights. We will not:
• Deny you goods or services
• Charge you a different price or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Provide you a different level of quality goods or services
• Suggest that you may receive a different price or rate for goods or services or a different level of goods or services
Sale of Personal Information
JW Pepper does not sell personal information.
Personal Information we collect
|Category of Personal Information||Description||Do we collect||Do we sell?|
|Contact Information||Data elements that allow the business to identify, address
contact a customer
|Unique Identifier||Data elements that JW Pepper uses to identify you and link
records; customer number, account number, etc.
Source: transactional processing system
|Transaction and interaction Information||Data elements generated in the course of transactions with
business; purchase history and related records (returns, AR, etc.)
Source: customer and transactional processing system
|Online & Technical Information||Data elements generated in the course of use of the website.
address, data from cookies, web beacons, etc.
Source: 3rd party analytics and marketing automation
|Relationship information||Data elements that help JW Pepper understand the customer,
personalize its interactions with the customer, and develop the business
with the customer; teaching position, musical interests and hobbies
|Audio information||Voicemails left for the purposes of placing an order
|Financial information||Data elements collected for the purposes of payment||Yes*||NO|
|Geolocation data||Data elements that allow precise location – used to deliver
relative content to various geographic reasons
Source: web application
Personal Information Disclosed for Business Purposes
We engage certain trusted third parties to perform functions and provide services to us, including error monitoring, debugging, performance monitoring, payment processing, customer relationship, database storage and management, and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
• Transaction Processing
• Account maintenance/Customer service
• Act-On - https://www.act-on.com/privacy-policy/
• System support providers
• System support providers
Fair Information Practices
We will take the following responsive action, should a data breach occur:
We will notify you via email within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
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.
We 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, we 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 you from ALL correspondence.
191 Sheree Blvd
Exton, PA 19341