Privacy

Curt G. Joa, Inc. Privacy Statement

Last Revised: June 21, 2022

Curt G. Joa, Inc. and its subsidiaries and affiliates (“JOA”) created this Privacy Policy (“Policy”) to disclose our information gathering and dissemination practices for this website (https://www.joa.com).

Throughout this Policy, “information” includes personal information about you.

Please read this Policy carefully. If you do not want us to collect, use or disclose your personal information in the ways described in this Policy, please do not use our Services, provide us with your personal information, or authorize a third party to make your personal information available to us. By using our Services, providing us with your personal information or otherwise making your personal information available to us, you acknowledge that you understand that we may use your personal information as described in this Policy. Please note, as described in this Policy, we may receive your personal information from third parties who have not expressly advised you that they will disclose your personal information to us. If you have any questions about how we collect, use, protect, disclose or otherwise process personal information, including whether we have received your personal information from a third party, please contact us by email at info@joa.com. BY VISITING AND USING OUR WEBSITE, YOU ACKNOWLEDGE THE TERMS OF THIS PRIVACY POLICY.

CONTACT INFORMATION

By email: info@joa.com

By postal mail:

Curt G. Joa, Inc. – Privacy Inquiries
100 Crocker Ave.
Sheboygan Falls, Wisconsin 53085
United States of America

GENERAL INFORMATION ABOUT OUR COLLECTION AND USE OF PERSONAL INFORMATION

When we refer to “personal information” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. Please note, as used in this Policy, “personal information” does not include publicly available information from government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.

Our primary goals in collecting personal information are to provide and improve our Online Offerings, to conduct our business operations, to provide our Services, to communicate with you, and to enable visitors to our Online Offerings to enjoy and easily navigate them. We also collect personal information in a variety of ways.

The categories of personal information we collect and use in connection with our Services may fall into one or more of the categories described below. Please note, the types of personal information provided as examples for each category are not a representation that we will collect that specific type of personal information about you.

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers;

Customer records, such as a name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Please note, for purposes of the California Consumer Privacy Act (“CCPA”), this category of personal information constitutes any personal information described in subdivision (e) of Cal. Civ. Code 1798.80.

Legally protected characteristics, such as race, religion, sexual orientation, gender identity, gender expression, and age. Please note, for purposes of the CCPA, this category of information constitutes characteristics of protected classifications under California or federal law.

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Biometric information.

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.

Geolocation data.

Audio, electronic, visual, thermal, olfactory, or similar information.

Professional or employment-related information.

Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Depending on how you use our Services or otherwise interact with us, the following chart provides a general summary about the categories of personal information we may collect about consumers, the categories of sources from which the personal information is collected, our business or commercial purposes for collecting the personal information and the categories of third parties to whom we may disclose such personal information.

Sources of Personal InformationCategories of Personal Information CollectedBusiness or Commercial Purposes for Collecting Personal InformationThird Parties with Whom Personal Information May be Disclosed
Directly from individuals or otherwise generated directly by an individual’s use of the Services or other interactions with usIdentifiers
Customer records
Legally protected characteristics
Commercial information
Biometric information
Provide the Services
Assess and improve the Services
Track usage of the Services
Create and update customer profiles
Third party service providers
Third party business partners
Government agencies and related entities
Credit reporting agencies
Audio, electronic, visual, thermal, olfactory, or similar information
Inferences
Provide the Services
Assess and improve the Services
Track usage of the Services
Create and update customer profiles
Determine eligibility for credit and offers
Internal market research and analytics
Provide notifications about promotions and special offers
Generate statistical studies
Ensure the security and safety of the Services
Protect our rights and property
Respond to inquiries
Perform background checks
Process financial transactions
Predict preferences, interests and future gaming and spending activities
Data analytics providers
Automatically through our Online Offerings (including using cookies and other tracking technologies)Identifiers
Internet or other electronic network activity information
Geolocation data
Inferences
Provide the Services
Assess and improve the Services
Track usage of the Services
Create and update customer profiles
Third party service providers
Third party business partners
Digital advertising providers
Internal market research and analytics
Protect our rights and property
Ensure the security and safety of the Services
Detect security incidents
Predict preferences, interests and future gaming and spending activities
Internet service providers
Operating system and platform providers
Government agencies and related entities
From third party service providers, third party business partners and government agencies and related entitiesIdentifiers
Customer records
Legally protected characteristics
Commercial information
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information
Inferences
Provide the Services
Assess and improve the Services
Track usage of the Services
Create and update customer profiles
Internal market research and analytics
Generate statistical studies
Ensure the security and safety of our Services
Protect our rights and property
Respond to inquiries
Perform background checks
Process financial transactions
Detect security incidents
Predict preferences, interests and future gaming and spending activities
Third party service providers
Third party business partners
Government agencies and related entities
Credit reporting agencies
Data analytics providers
Digital advertising providers

WHAT ARE THE SOURCES OF PERSONAL INFORMATION WE GATHER FROM THOSE WHO VISIT THIS WEBSITE?

ORDER FORMS – Some areas of this website may allow you to order products or services, whether for a fee. In connection with these transactions, we collect data necessary to complete the transaction and that is furnished by you. This may include contact information, including first and last name, company name, postal address and country, email address and telephone number, comments and information provided in connection with products and services.

SURVEYS – At times, you may be asked to complete survey questions that appear on this website.

EMAIL – On several screens of this website, you also have an opportunity to communicate with us by email. You may also choose to provide your email address to receive communications from us or third parties.

CONTACT/INTERACT – You also may provide information when you contact or otherwise interact with us or a third party (for example, your search queries on this website, reporting an issue with this website).

Information Collected and Stored Automatically. When you browse this website, you and your web browser may also transmit information that we automatically collect. We can automatically collect information about you, including IP address (the Internet address of your computer), domain name of your Internet service provider, your geographic location, and aggregated information that cannot be used to specifically identify you when you use or visit this website, the web pages you visit and the time of your visit, and other click-stream data. This information may be combined with other personal information you have provided. The only other type of information automatically provided to us is the type of computer, operating system, and browser you are using. This information is provided by your browser, which we use to improve the performance of this website.

We also can collect information about you from publicly accessible sources, our subsidiaries, and affiliates, and our third-party service providers and other partners.

We can combine any of the information we collect from or about you and use it in the manner described in this Policy.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to communicate with you when necessary, in connection with your use of this website, to process and respond to your questions and comments, or to send you material and information you request. We may use your information, subject to applicable law, including:

  • To personalize and enhance your website experience and to allow us to deliver the type of content and product information in which you are most interested;
  • To consider your suggestions;
  • Possibly to respond directly to you for clarification;
  • To process your request;
  • To try to and answer your questions;
  • To register you for an event, contest, or sweepstakes;
  • To allow you to participate in surveys;
  • To provide you with email messages and other promotional information regarding upcoming events, new services and general information about our products and services. (NOTE: You may elect not to receive these communications);
  • For the purposes for which you provided it (for example, engaging in a transaction);
  • To provide or to facilitate providing you with products and services;
  • To provide this website to you, including any notifications or updates relating to this website;
  • To notify you about changes to this website, our policies, Terms or any products or services we offer or provide though it;
  • To send you information about your relationship or transactions with us;
  • To record that you have visited or used this website;
  • To contact you with information, including marketing information, that we believe will be of interest to you;
  • To customize our marketing;
  • For testing, research, analysis and product and service development that we or a third party can perform regarding this website (for example, user base and website usage);
  • To create anonymous data or de-identified data, which we or a third party can do and which we or a third party can use for any purpose;
  • To aggregate data, which we or a third party can compile, and which we or a third party can do and can use for any purpose;
  • To analyze how you use this website and to analyze this website, which we or a third party can do;
  • To call you via telephone and send you electronic communications (for example, emails);
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
  • To investigate, and deter against fraudulent, unauthorized, or illegal activity and otherwise protect our users and our business;
  • To administer and troubleshoot this website;
  • In any other way we describe to you at the time you provide your information; and
  • As otherwise stated in this Policy and our Terms.

We may also use your website information in order to help diagnose problems with this website. We may use all information we collect to analyze statistical use patterns and demographic data (basically, where our visitors come from and what demographic characteristics they have) and to improve this website to better serve our customers. We use your IP address to help diagnose problems with our servers, and to administer this website. Your IP address is used to help identify you and your shopping cart and to gather broad demographic information. We may also prepare and keep statistical records and other data about you and other users of this website. We may hire third parties to help us collect and analyze such data, and we may share such statistical data with third parties. We use this information to help us make this website more useful to visitors — to learn about the number of visitors to this website, what part of this website they are interested in, how long the use this website, and the types of technology our visitors use.

Please also see WHERE WE STORE YOUR INFORMATION, DISCLOSING YOUR INFORMATION TO OTHERS, YOUR CHOICES REGARDING YOUR INFORMATION, YOUR RIGHTS and RETENTION below.

WHERE WE STORE YOUR INFORMATION

We store the information that we collect on our systems. By using this website, you understand that your information can be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country.

DISCLOSING YOUR INFORMATION TO OTHERS

Information may be disclosed to third parties in accordance with this Policy, subject to applicable law. Please note that you can choose not to share certain information by opting out of further transfer of your data to others besides JOA.

We may disclose your information with third parties with whom we have partnered to provide specific services to us or services on our behalf in connection with this website (for example, providing products or services, marketing, data analysis, enhancing the information collected from or about you, etc.). We can use third parties to perform any of the actions or activities allowed under this Policy. We can share information about you that they need to perform their functions and in accordance with our agreements with them.

In addition, we may be required to disclose your information to third parties to comply with law or in response to subpoenas, warrants, or court orders or in connection any legal process or cooperate with government or law enforcement agencies or officials or private parties, (including laws outside of your country of residence), fraud prevention, regulation, and other legal action or if we reasonably believe it is necessary to do so to protect us, our customers, or the public.

We also may be required to disclose your information to third parties to:

  • Enforce or apply our Terms and other agreements;
  • Protect our rights, reputation, safety, and property or in an emergency, or that of our users or others;
  • Resolve disputes;
  • Protect against legal liability;
  • Establish or exercise our rights to defend against legal claims; or
  • Investigate, prevent, or take action regarding suspected illegal activities, the rights, reputation, safety or property of us, users or others, violation of our Terms, policies or agreements or as otherwise required by law.

If we become involved in a merger, acquisition, sale of assets, joint venture, securities offering, financing, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information to a third party or parties in connection therewith and it can be used subsequently by such third party or parties.

We may disclose your information to any subsidiary or affiliate of ours for purposes consistent with this Policy. Any subsidiary or affiliate of ours will be required to maintain that information in accordance with this Policy.

We or a third party can analyze how you use this website and can analyze this website.

We can share aggregated or de-identified information relating to visitors to and users of this website with any third party for any purpose.

We or a third party can analyze how you use this website and can analyze this website.

We can share your information other than as described in this Policy if we notify you and you consent to the sharing thereof.

We can share your information with any other individual or third party or service provider at your request.

We can disclose your information for any other purpose we describe to you at the time you provide your information.

Please also see WHAT PERSONAL INFORMATION DO WE GATHER FROM THOSE WHO VISIT THIS WEBSITE? above and DO NOT TRACK, ONLINE TRACKING AND OTHER TECHNOLOGIES below.

DO NOT TRACK, ONLINE TRACKING AND OTHER TECHNOLOGIES

At this time, we do not respond to “Do Not Track” signals sent from web browsers or other mechanisms that provide users the ability to exercise choice regarding the collection of personally identifiable information about a user’s online activities over time and across third party Internet services.

Third parties may collect personally identifiable information about an individual user’s online activities over time and across different websites when a user uses this website.

We may place small data files, called “cookies,” in the browser file of your computer’s hard drive. Persistent cookies remain on the visitor’s or user’s computer after the browser has been closed. Session cookies exist only during a visitor’s or user’s online session and disappear from the visitor’s or user’s computer when they close the browser software. These cookies automatically identify your browser to our server whenever you interact with this website. We use the cookies to record website statistics. Most browsers automatically accept the cookies, but you usually can change your browser setting to prevent the acceptance of cookies. Certain web pages may not function properly if you choose not to accept cookies.

Below is a link to a resource regarding online tracking:
For Google Analytics, please see https://policies.google.com/privacy, https://policies.google.com/technologies/partner-sites, https://www.google.com/analytics/terms/ and https://tools.google.com/dlpage/gaoptout.

LINKS TO OTHER WEBSITES

We may create links to other websites that we think may be of interest to you. We do not endorse any other websites, and this Policy applies only to your use of this website. We have not reviewed the privacy policies of any websites we link to this website, and you should read the privacy policies of each website you visit to determine what information that website may collect about you.

STATE SPECIFIC RIGHTS

A: California.

1: California’s Shine the Light Law. Under California’s Shine the Light Law, certain businesses are required to respond to requests from California residents asking about the disclosure of personal information to third parties for third party marketing purposes. Alternately, such businesses may adopt a policy of not disclosing personal information to third parties for marketing purposes if a California resident has opted-out of such information sharing. We have adopted an opt-out policy. If you wish to opt-out of our sharing your personal information with third parties for marketing purposes, please follow the instructions in Section III(F) above.

2: California Consumer Privacy Act. The California Consumer Privacy Act of 2018 as amended and including any regulations adopted by the California Attorney General (collectively, “CCPA”) grants certain privacy rights to California consumers, including the right to (A) know what categories of personal information we have collected about California consumers during the preceding 12 months, including the categories of sources from which that information was collected, the business or commercial purpose for which it was collected, and the categories of third parties with whom the information was shared (see Section I above); (B) request to know what personal information we have collected, used, disclosed, and sold about you during the preceding 12 months (see Section IV.B.1 below); (C) request that we delete your personal information (see Section IV.B.2 below); and (D) opt-out of the sale of your personal information to third parties (see Section IV.B.3 below). These rights, which are discussed more fully below, are subject to some important exceptions, which are intended, among other things, to protect the integrity and privacy of your personal information. You have the right not to be discriminated against for exercising your CCPA rights. You also have the right to designate an authorized agent to exercise your CCPA rights on your behalf.

If you need information on how to exercise your CCPA rights in an alternative, accessible format due to a disability, please send an email with your name and contact information to PrivacyInquries@joa.com.

a: REQUESTS TO KNOW ABOUT YOUR PERSONAL INFORMATION

You have the right to request that we disclose to you, for the 12-month period preceding the date we receive your request, the following: (1) the categories of personal information we have collected about you, (2) the categories of sources from which personal information was collected about you, (3) the business or commercial purpose for which your personal information was collected or sold, and (4) the categories of third parties to whom we have sold or disclosed your personal information. In addition, you have the right to request that we disclose to you the specific pieces of personal information we have about you. If you are a California resident, and wish to request this information, please call us at 920-467-6136 or email us at Info@joa.com and indicate that you wish to request this information and provide the identifying information requested. All requests are subject to verification of your identity to protect the privacy and security of your personal information. We are required to fulfill these requests no more than twice within a 12-month period.

b: REQUESTS TO DELETE YOUR PERSONAL INFORMATION

You have the right to request that we delete your personal information, subject to certain exceptions such as our need to comply with legal obligations, fulfill orders, complete transactions, etc. If you are a California resident, and wish to request deletion of your personal information, please call us at 920-467-6136 or email us at Info@joa.com. and indicate the at you wish to delete your personal information and provide the identifying information requested. All deletion requests are subject to verification of your identity. If we delete any of your personal information pursuant to a deletion request, we will also instruct our service providers (if any) to delete your personal information from their records, subject to applicable legal requirements.

c: REQUESTS TO OPT-OUT OF SALE OF YOUR PERSONAL INFORMATION

You have the right to opt-out of having your personal information sold to third parties. In the past twelve (12) months, JOA has not sold any personal information to third parties with respect to the Services or any Wagering Account. If we decide to sell personal information in the future, we will update this Policy and the Services to make those rights available to you. Even though we do not currently sell any personal information, if you are a California resident and wish to opt-out of any future sale of your personal information to third parties, please contact us by telephone at 920-467-6136 or email us at Info@joa.com and indicate that you wish to opt-out of any future sale of your personal information to third parties and provide your identifying information as requested. Please note that even if you opt-out of the future sale of your personal information, we may still (1) share your personal information with service providers and other entities for business purposes consistent with the CCPA, and (2) share your personal information in connection with certain business transactions consistent with Section II above.

d: VERIFICATION PROCEDURES

To verify requests made pursuant to the CCPA, we may require two (2) or more pieces of identifying information that match information maintained by us or, if you have a Wagering Account, to verify your identity through your Wagering Account. In some cases, we may require additional identifying information and a signed declaration attesting to your identity. In situations where we receive a request from an authorized agent on your behalf, we may require written proof that the agent is, in fact, authorized to act on your behalf and we may take additional steps to verify your identity and the authorized agent’s identity. A request to opt-out pursuant to Section IV.B.3 above need not be verified. However, if we have a good-faith, reasonable basis to believe that an opt-out request is fraudulent, we may deny the request and provide an explanation of the reason for the denial.

In certain circumstances, we may decline a request to exercise the Right to Know (IV.B.1) or Right to Delete (IV.B.2) described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

SECURITY

Although we use physical, electronic, and administrative safeguards to help protect the information you submit via this website from accidental or unlawful destruction, loss, or alteration and from unauthorized access, use, or disclosure, we cannot guarantee its absolute security. No Internet or electronic communication transmission is ever fully secure or error free. Internet or electronic communications, including those sent through this website, may not be secure. You should use caution whenever submitting information through this website and take special care in deciding which information you provide us with.

YOUR CHOICES REGARDING YOUR INFORMATION

You have choices regarding your information on this website.

1. Email Communications. You can make changes regarding receiving email communications from us by contacting by telephone at 920-467-6136 or by emailing us at Info@joa.com.

2. Withdrawing Consent. You can withdraw your consent to our processing of your personal information at any time by emailing us at Info@joa.com.

RESIDENTS OF THE EUROPEAN UNION

1. European Union Rights. Under the General Data Protection Regulations (“GDPR”), the following rights apply in certain circumstances only to individuals in the European Union.

  • To request confirmation of whether we process your personal information, details of the information that we hold about you and how we use it and to access your personal information and to be provided with a copy, please email us at Info@joa.com.
  • To request rectification of your personal information: if you believe that the personal information, we hold about you is inaccurate, you can request that we correct it and can also request us to complete personal information about you which is incomplete by emailing us at Info@joa.com.
  • To request deletion of your personal information on one of the following grounds, please email us at Info@joa.com:
    • you believe that it is no longer necessary for us to hold your personal information;
    • we are processing your personal information based on legitimate interests, and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing;
    • where our processing of your personal information is for direct marketing purposes, and you object to such processing;
    • you have provided your personal information to us with your consent, and you wish to withdraw your consent and there is no other ground under which we can process your personal information; or
    • you believe the personal information we hold about you is being unlawfully processed by us.
  • To request that we restrict processing of your personal information on one of the following grounds, please email us at Info@joa.com.
    • where you believe the personal information, we hold about you is inaccurate and while we verify accuracy;
    • we want to delete your personal information as the processing is unlawful, but you want us to continue to store it;
    • we no longer need your personal information for the purposes of our processing, but you require us to retain the information for the establishment, exercise, or defense of legal claims; or
    • where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.
  • To request to object to our processing of your personal information where it is based on our legitimate interests or where such processing is for direct marketing purposes, please email us at Info@joa.com.
  • Data portability: to request to receive the personal information that you have provided to us in a structured, commonly used, and machine-readable format and to transmit this to another data controller (where technically feasible) where the processing is based either on consent or on the performance of a contract, and the processing is carried out by automated means, please email us at Info@joa.com.
  • To lodge a complaint with a supervisory authority in an applicable European Union country if your request or inquiry is not satisfactorily resolved by us after emailing us at Info@joa.com.

2. Processing. We process the information of individuals in the European Union based on one or more of the following legal bases:

  • Performance of a contract: we or a third party process your website information to perform the contract that you have with us (for example, providing this website to you).
  • Legitimate interests: we or a third party can use your information where we or such third party have legitimate interests to do so (for example, analyzing users’ behavior on this website for assessing website usability and processing information for business or legal purposes).
  • Consent: we can ask for your consent to use your information for specific purposes. You can withdraw your consent to our processing of your personal information at any time by emailing us at Info@joa.com.
  • Legal obligation: we may be required to use your information to comply with a legal obligation (for example, complying with law, in response to legal process or cooperating with government or law enforcement agencies or officials or private parties).
  • The processing is necessary to protect the vital interests of our users or of others (for example, processing personal information, including disclosing data with law enforcement agencies in case of threats to the safety of users or of others).

We will retain your personal information for as long as reasonably necessary for the purposes described in this Policy, while we have a legitimate business need to do so in connection with your use of this website, or as required by law (for example, for legal, tax, accounting, or other purposes), whichever is the longer.

To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

CHILDREN

We do not knowingly collect personal information from children under age 18. If you are under the age of 18, please do not access, use, or submit any personal information through this website. If you have reason to believe that we may have accidentally received personal information from a child under age 18, please contact us immediately by email at Info@joa.com or by telephone at 920-467-6136.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or modify this Policy at any time and from time to time without prior notice. Please review this Policy periodically, and especially before you provide any information. This Policy was made effective on the date indicated above.