Privacy Policy

Last Updated: March 23, 2026

1. Overview

This Privacy Policy describes how Just Holdings, Inc. (“Just,” “Company,” “we,” “us,” or “our”) collects Personal Data about you, how we collect it, how we use it and with whom we share it. This Privacy Policy also describes the choices you can make about how we collect and use your Personal Data. This Policy does not apply to the practices of companies that we do not own or control, or to people whom we do not employ or manage.

By using or interacting with our website (the “Website”), you agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy is subject to and incorporated within the Website’s Terms of Service (“Terms”), including its provisions on liability and dispute resolution. Capitalized terms not otherwise defined in this Privacy Policy shall have the meanings ascribed to them in the Terms. IF YOU DO NOT CONSENT AND AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU CANNOT, AND WE DO NOT AUTHORIZE YOU TO, ACCESS, BROWSE, OR USE THE WEBSITE.

Our processing of personal information, such as your name, address, e-mail address, or telephone number, will be undertaken consistent with the requirements of applicable privacy laws, including, but not limited to, the California Consumer Privacy Act, the California Privacy Rights Act, the Virginia Consumer Data Protection Act of 2021, the Colorado Privacy Act of 2021, and the Utah Consumer Privacy Act of 2022, the Connecticut Data Privacy Act of 2022, the Texas Data Privacy and Security Act, the Oregon Consumer Privacy Act, the Montana Consumer Data Privacy Act, the Tennessee Information Protection Act of 2023, the Iowa Consumer Data Protection Act of 2023, the Delaware Personal Data Privacy Act of 2023, the Nebraska Data Privacy Act of 2024, the New Hampshire Privacy Act of 2024, and the New Jersey Data Privacy Act of 2024, the EU General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (UK GDPR), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA).

2. Definitions

“Cookies” are small computer files transferred to your device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Website. We use Cookies to: (i) improve and tailor the Website, (ii) customize advertisements, (iii) measure performance, (iv) store authentication so re-entering credentials is not required, (v) customize user experiences, and for (vi) analytics and fraud prevention. For more information on Cookies, including how to control your Cookie settings and preferences, visit http://www.allaboutCookies.org. You can also manage Cookies in your web browser (for example, Edge, Explorer, Chrome, Safari). If you choose to change your settings, you may find that certain functions or features of the Website will not work as intended. The following details the types of Cookies we use and why we use them:
1. Necessary Cookies. These Cookies are essential to enable you to move around a website and use its features. Without these Cookies, services you have asked for, like adding items to an online order, cannot be provided.
2. Performance Cookies. These Cookies collect information about how you use the Website. Information collected includes, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These Cookies do not collect information that personally identifies you and only collect aggregated and anonymous information. Performance Cookies are used to improve the user-friendliness of a website and enhance your experience.
3. Functionality Cookies. These Cookies allow the Website to remember choices you make (such as your username, language preference, or the area or region you are in) and provide enhanced, more personal features. These Cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of the Website. The information these Cookies collect may be anonymized, and they cannot track your browsing activity on other websites.
“Data Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
“Data Processor” or “Service Provider” means any natural or legal person who processes the data on behalf of the Data Controller. We may use the service of various Service Providers in order to process your data more effectively.
“Data Subject” is any living individual who is using our Website and is the subject of Personal Data. For the purpose of this Privacy Policy, you are a Data Subject.
“Personal Data” means information about a living individual who can be reasonably identified from such information (or from those and other information either in our possession or likely to come into our possession).
“Usage Data” includes tracking technologies and consists of data that is collected automatically by the use of the Website itself (for example, dates and times of Website visits or usage, the duration of a web page visit or the use of a mobile app, IP addresses, browser characteristics, device characteristics, operating system, language preferences, referring URLs and information on actions taken on our Website).

3. How We Collect Your Personal Data

We collect information in different ways from individuals who access the Website. We collect information in the following ways:

Directly from you:
1. Collected from website forms.
2. When you upload User Content to the Website.
3. Through customer relationship management (“CRM”) data entry.
4. When you contact us, provide feedback, or participate in surveys.
Automatically from you:
1. Through third party tools used to collect User behavior, such as through Cookies or other tracking technologies.
2. Through public records requests.
3. Through web analytics tools.
4. Through email marketing platforms.
5. Through social media advertisement platforms.
6. Through cookies and tracking pixels.
7. We may also receive reports from our Service Providers or other third-party data vendors on an individual as well as aggregated basis.

4. What Types of Personal Data We Collect

We collect different information from you depending on how you engage with us. Information will be collected from business entities, individuals, Website visitors (both anonymous and identified), existing clients, and prospective clients.

We collect your name, email address, phone number, physical address, company name, company title, company role, and other registration information.
We collect information you upload to the Website.
We collect behavioral data, including your Website visits, page views, amount of time on the site, and clicks.
We collect form submission data, including contact forms, quote requests, and downloads.
We collect communication records, including email opens, clicks, and replies.
We collect social and professional data, including LinkedIn profile URLs and job titles.
We collect information you provide when you contact us, provide feedback, or participate in surveys.
We automatically collect Usage Data through your use of the Website, including, but not limited to, the number of policies processed, tasks completed, features used, and frequency of log-ins.
Information about the devices you use to access the Website, including IP address, browser type, operating system, cookies, and access times.

5. Collection and Use of Sensitive Personal Information

We have collected the following categories of sensitive personal information from consumers:

Complete account credentials.
Mail, email, or text message contents.

We do not use or disclose sensitive personal information for purposes other than those specified in the CCPA/CPRA.

6. How We Process and Use Your Personal Data

We may process and use your Personal Data primarily to perform a contract with you, and to otherwise deliver the Website or a service that you request, including:

To create your account.
To provide, maintain, and improve the Website, including to anonymize, deidentify and aggregate your Personal Data, following which processing it will no longer be considered Personal Data.
To respond to your requests and provide customer support. We retain support data for a reasonable period consistent with operational needs.
For any other purpose with your consent.

We may also process your Personal Data because it is necessary for our or a third party’s legitimate interests and it’s not overridden by your rights. In this respect, we may use your Personal Data:

To send you technical notices, updates, and administrative messages.
To track Website performance, to make your visit better, and for aggregate Website analytics.
To monitor and analyze trends, usage, and activities in connection with the Website.
For marketing and outreach.
For retargeting.
For business development and lead qualification.
For analytics and campaign optimization.
For legal and compliance recordkeeping.
For referral tracking.
We use Cookies and LSOs (Local Shared Objects) to remember Users’ preferences (e.g. search filters), for authentication, for source tracking, for analytics, or for product recommendations.
We may use your Personal Data, including information derived from your use of the Website and User Content metadata, to market and promote the services of our affiliates. This may include contacting you about their services that may be relevant to you. You may opt out of such marketing communications at any time by following the unsubscribe instructions in any marketing email or by contacting us at user.privacy@just.holdings.

We may also process your Personal Data for our compliance with our legal obligations. In this respect, we may use your Personal Data for the following:

To detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities.
When necessary to enforce or apply our Terms and other related agreements.
To protect our rights or the property or safety of our employees, Users or members of the general public.

7. With Whom Will We Share Your Personal Data

We may share your Personal Data:

If we have received your permission beforehand.
With Service Providers who perform services on our behalf, including cloud hosting providers, analytics providers, email marketing platforms, advertisement platforms including, but not limited to: Meta, LinkedIn, Google, Adroll, and CTV through MNTN (https://mountain.com/), CRM platforms and customer support tools. These service providers are contractually obligated to use your information only as necessary to provide services to us.
With our employees, contractors, and virtual assistants.
With our affiliates for purposes consistent with this Privacy Policy.
Under certain circumstances, if required to do so by law or in response to valid requests by public authorities or law enforcement (e.g. a court or a government agency).
If in good faith, we believe that such action is necessary to comply with a legal obligation or to protect and defend our rights or property.
To a successor entity upon a merger, consolidation or other corporate reorganization in which we participate or to a purchaser of all or substantially all of our assets to which this Website relates.

8. Your Data Protection Rights and Choices

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us using the details set out below. You may have the right to:

Access or update the information we have on you. Find out if we use your Personal Data, access your Personal Data and have it corrected or amended if it is inaccurate or incomplete.
Withdraw consent. Withdraw any express consent that you have provided to the processing of your Personal Data at any time without penalty.
Object. You have the right to object to our processing of your Personal Data.
Data portability. Obtain a transferable copy of some of your Personal Data which can be transferred to another provider when the Personal Data was processed based on your consent.
Rectification. If you believe your Personal Data is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Data, you may also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
Deletion or restriction. Request your Personal Data be deleted or restricted under certain circumstances.
Opt-out of targeted or behavioral advertising. You may have the right to opt out of cross-context behavioral / targeted advertising, which is based on the Personal Data you share with our Website, as well as data collected from third party websites.

U.S. state privacy rights may include access, deletion, correction, portability, and the right to opt out of targeted advertising and certain profiling. We provide an appeal process for denied requests as required by law. If you wish to exercise any of these rights, or raise a complaint on how we have handled your Personal Data, please contact us at user.privacy@just.holdings or via the details below.

You additionally have choices regarding the collection, use, and sharing of your Personal Data.

You have a right at any time to stop us from contacting you for promotional marketing purposes. If now or in the future you receive promotional or electronic newsletter communications from us, you may indicate a preference to stop receiving such communications from us, and you will have the opportunity to “opt-out” by clicking the “Unsubscribe” hyperlink at the bottom of all such communications. Notwithstanding your indicated email marketing preferences, we may continue to send you administrative emails regarding the Website, including, for example, order confirmations or updates to our Privacy Policy or the Terms.
You may be able to configure your browser to accept or reject all or some Cookies, or notify you when a Cookie is set — all browsers are different, so check the “Help” menu of your particular browser to learn how to change your Cookie preferences. Users can control the use of Cookies at the individual browser level. Various browsers may offer their own management tools for removing HTML5 LSOs.

9. International Data Transfers

Visiting our Website from outside the United States:

Our Website is intended for users within the U.S. We store and process all Personal Data within the U.S.

If you are visiting our Website from outside the United States, please be aware that your information will typically be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. We take reasonable steps to ensure that your Personal Data is protected. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

10. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to perform a contract with you, comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Upon termination of your account, we will delete or anonymize your information within thirty (30) days of written request, except that we may retain:

Information required for legal, compliance, or financial reporting purposes;
Aggregated or anonymized data that cannot reasonably identify you; and
Information derived from User Content that has been used to train or improve our models, provided such information has been deidentified.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods. We may retain reviews to preserve transparency and Website integrity even after account closure, to the extent permitted by law; support tickets are retained per our retention policy. Criteria for retention include legal requirements, security, and product needs.

11. Security of Data

No method of transmission over the Internet, or method of electronic storage is 100% secure. We take precautions to ensure that our visitors’ Personal Data is secured and we strive to use commercially acceptable means to protect your Personal Data, but we cannot guarantee its absolute security.
We use a variety of industry-standard technical, contractual, administrative and physical security measures and procedures to help protect your Personal Data from unauthorized access, use, alteration or disclosure. Unless otherwise provided, we restrict access to Personal Data to those employees who need access to perform their job functions. Please note that despite our best efforts, no one can guarantee the security of Personal Data. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of Personal Data at any time.
In the event of a Security Incident (meaning any actual or reasonably suspected unauthorized access, disclosure, misappropriation, theft, loss, acquisition, use, modification, or alteration of the availability of your Personal Data or User Content), we will notify affected users as soon as practicable, but no later than forty-eight (48) hours after becoming aware of such Security Incident, such notification to be provided in writing (by email) to the contact information associated with your account. The notification will include, to the extent known: (i) the nature and scope of the Security Incident; (ii) the categories and approximate number of individuals and records concerned; (iii) the likely consequences of the Security Incident; and (iv) the measures taken or proposed to be taken to address the Security Incident. We will cooperate with affected users in investigating any Security Incident and will comply with all applicable breach notification laws.
Where required by applicable data protection laws, we will conduct data protection impact assessments for processing activities that are likely to result in a high risk to the rights and freedoms of individuals. We will cooperate with users in connection with any data protection impact assessments or privacy risk assessments required under applicable law.

12. Service Providers

We may employ Service Providers, to process Website-related data on our behalf, to perform Website-related service or to assist us in analyzing how our Website is used. Each of these Service Providers is contractually obligated to provide services to us in a manner consistent with this Privacy Policy.

As displayed in the chart below, these third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose and must comply with the requirements for third party processors set forth in this Privacy Policy.

Category	Examples	Collected?	Categories of Recipients
Identifiers	Name, address, e-mail address, IP address	Yes	Organizations providing services to Company
Personal information categories listed in the California Customer Records statute	Name, professional-related information; and employment-related information	Yes	Organizations providing services to Company
Protected classification characteristics under California or federal law	Name, age, citizenship, nationality, ancestry, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, proof of eligibility to work	Yes	Organizations providing services to Company
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with the Website	Yes	Organizations providing services to Company
Geolocation data	Location and movement data	No
Professional or employment-related information	Proof of eligibility to work, resumé, other professional-related information and employment-related information	Yes	Organizations providing services to Company
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
Non-Public Education Information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	No
Inferences from the foregoing	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

13. Children’s Privacy and International Considerations

Our Website is not intended for anyone under the age of 18 (“Children”).

We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us at user.privacy@just.holdings or at the address provided below. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Data is processed and stored in the United States using storage methods including, but not limited to: CRM, cloud storage, managed employee devices, email marketing platforms, and third-party vendor systems. We use industry standard safeguards but cannot guarantee absolute security. If your personal data is subject to GDPR or UK GDPR, we will transfer personal data from the European Union to a location outside the European Union only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.

14. Third Party Web Services

The Website may contain links or content from third party websites. A link or content from a third-party website does not mean we endorse that website, the accuracy of information presented, or the persons or entities associated with that website. If you visit a third-party website, you are subject to the privacy policy of the applicable third party and we are not responsible for the policies and/or practices of any third party. We encourage you to ask questions before you disclose your information to others.

15. Changes to This Privacy Policy

From time-to-time we may modify, change, update, add to, remove portions of or otherwise alter this Privacy Policy. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Website of any substantive changes, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. If you object to any such changes, you must immediately cease using the Website.

16. Contact, Questions, or Feedback

When we receive formal written complaints, it is our policy to contact the person regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Data that cannot be resolved between us and an individual.

17. Contact Us

If you have any questions about our Privacy Policy, you can always contact us in these ways:

Send us an e-mail: user.privacy@just.holdings

Write to us at:

Just Holdings, Inc.
1593 E. Edgewood Dr.
Whitefish, MT 59937
Attention: Privacy