Privacy

JORDAN PARK TRUST COMPANY PRIVACY NOTICE

Last Updated August 29, 2023

This privacy notice (“Privacy Notice” or “Notice”) describes how Jordan Park Trust Company LLC (“JPTC,” “we,” “us,” “our”) collects and processes Personal Information (defined below) we collect while conducting business or visiting our website and describes rights residents of certain states may have with respect to their Personal Information. It does not apply to information we collect about individuals when acting in their capacity as employees, independent contractors, or job applicants.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular customer or household.

Notice at Collection: Personal Information We Collect

JPTC collects the following categories of Personal Information:

Personal identifiers: Name, address, email address, telephone numbers, social security number, tax identification number, birth date, IP address or other unique identifier, account name and password, identification documents for anti-money laundering (“AML”) that may be received in account documents and related forms and other similar information, eligibility to work in the U.S. and visa status information.
Financial information: Bank account information, account activity, assets, income, investment experience and activity, financial goals, and account balances.
Commercial information: Records of products or services purchased or considered, consuming histories or tendencies.
Internet or other electronic activity information: Device and browser type, your browsing and search history on our website, and information regarding your interaction with our website.
Professional information: Current and former Job titles, employers
Inferences drawn from Personal Information collected.
Sensitive Personal Information: social security number, tax identification number, eligibility to work in the U.S. and visa status information.

We collected the same categories of Personal Information in the 12 months prior to the date of this Notice.

Notice at Collection – Purposes for Collection of Personal Information

We use the Personal Information we collect to provide financial products and services to our customers, to manage and administer your account(s) and to communicate with you about account related activities on an ongoing basis, to market to existing and prospective customers, or information security and fraud detection, and to maintain our relationships and fulfill our obligations to our customers.

We may also use your Personal Information to enforce or defend our rights, or those of another customer or other third party. JPTC will collect and use Personal Information in the course of business for tasks such as, the execution of account documents, for the legitimate interests of JPTC and to enable JPTC in complying with its legal and regulatory obligations.

Notice at Collection – Sale or Sharing of Personal Information

JPTC does not sell Personal Information or share it for the purposes of cross-context behavioral advertising.

Notice at Collection – Retention

JPTC complies with applicable legal or regulatory obligations regarding data retention and for any other legitimate business reasons, and we may retain Personal Information for longer or shorter durations, as appropriate, or required by law. We will retain Personal Information for as long as we have an existing customer account. We expect to delete Personal Information once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining that Personal Information, currently seven years from the date an account closes, or at the conclusion of litigation (including appeals) or as required by law, whichever is later.

Sources From Which We Collect Personal Information

We collect Personal Information from our customers’ business contacts, as well as from other financial institutions or referral sources. We may also automatically collect information through the use of cookies and other tracking technologies.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose Sensitive Personal Information to infer characteristics about individuals or for any purposes other than to operate our business.

Disclosures of Personal Information For Business Purposes

The following chart describes the categories of Personal Information we have disclosed to third parties for a business purpose in the 12 months prior to the date of this Privacy Notice:

Categories of Consumers’ Personal Information	Categories of Third Parties With Which We Shared Personal Information for a Business Purpose
Personal identifiers: Name, address, email address, telephone numbers, social security number, tax identification number, birth date, IP address or other unique identifier, account name and password, identification documents for anti-money laundering (“AML”) that may be received in account documents and related forms and other similar information	Service providers that provide customer relationship management; facilitate account management; process transactions and investments; maintain customer records and provide centralized administrative and marketing services for customers; investigate and resolve complaints and manage litigation; monitor IT systems for data security incidents, fraud, or crime detection or for regulatory reasons; comply with applicable AML policies; assist us in operating, analyzing, and displaying content on our website; provide analytics information; marketing services; provide advertising and marketing services; provide website hosting, webcast and teleconference services; provide legal and accounting services.
Financial information: Bank account information, insurance information, account activity, investment activity and financial goals, and account balances.	Service providers that provide customer relationship management; facilitate account management; process transactions and investments; maintain customer records and provide centralized administrative and marketing services for customers; investigate and resolve complaints and manage litigation; monitor IT systems for data security incidents, fraud, or crime detection or for regulatory reasons; comply with applicable AML policies; provide legal and accounting services.
Commercial information: Records of products or services purchased or considered, consuming histories or tendencies.	Service providers that provide customer relationship management; provide advertising and marketing services.
Internet or other electronic network activity information: Device and browser type, browsing and search history on our website, and information regarding interaction with our website.	Service providers that provide data security services and cloud-based data storage; provide customer relationship management; host our website and assist with other IT-related functions; provide website hosting, webcast and teleconference services; advertise and market our products; and provide analytics information.
Professional information: Current and former Job titles, employers.	Service providers that assist with operational due diligence, and meeting related regulatory requirements.
Inferences drawn from Personal Information collected.	Service providers that provide advertising and marketing services; provide analytics services provide customer relationship management; provide investment opportunity management.

* – Denotes Sensitive Personal Information

Business Purposes for the Disclosure of Personal Information

JPTC may disclose each of the categories of the Personal Information we collect to third party service providers, governmental authorities, or to other third parties including other financial institutions as directed by the customer or otherwise required or permitted by law for the following purposes: entering into account documents; processing transactions and investments; maintaining customer records and providing centralized administrative and marketing services for current and prospective customers; investigating and resolving complaints and recording calls and managing litigation; monitoring electronic communications and other IT systems for data security incidents, fraud, or crime detection or for regulatory reasons; and to satisfy our legal obligations.

Additional Information About How We May Disclose Personal Information

We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property, or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your Personal Information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Cookies and Other Tracking Technologies

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit our website, we may place a “cookie” or other online tracking devices (e.g., web beacons) that recognizes you. The cookies and other tracking technologies may also collect information about your IP address or actions taken in connection with our website. We may use cookies or similar tracking technologies to capture information about the use of our websites, including to improve your user experience. Accordingly, we may store and retrieve information on your device through the use of cookies and similar technologies. Some of these technologies are from third parties. For example, we may use analytic processing technology such as Google Analytics to collect information to help us understand how visitors engage with our website. Click this link (https://marketingplatform.google.com/about/analytics/terms/us/) to learn more about how Google collects and processes information in connection with the services it provides to us.

Your Privacy Rights – California

If you are a resident of California, you may have rights under the California Consumer Privacy Act of 2018 (“CCPA”), as described in this section of our Privacy Notice.

Your Right to Access and Request Disclosure of Information We Collect and Share About You

JPTC is committed to ensuring that you know what information JPTC collects and shares about you. You can submit a request to JPTC for the following information:

The categories of Personal Information that JPTC has collected about you.
The categories of sources where JPTC collected the Personal Information.
The business or commercial purposes for why JPTC collected the Personal Information.
The specific pieces of Personal Information we collected about you.
The categories of third parties with whom JPTC shared your Personal Information.
The categories of Personal Information that we’ve shared with service providers who provide services for us.

Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.

Your Right to Request Deletion of Personal Information We Have Collected About You

Upon your request, we will delete the Personal Information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.

To exercise your rights to access, delete, or correct your Personal Information, contact JPTC at information@jptc.com or (603)929-2700. Requests are typically free of charge.

Your Right to Request to Correct Personal Information We Hold About You

You have the right to request that we correct Personal Information we hold that you believe is not accurate. We will take steps to determine the accuracy of the Personal Information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the Personal Information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct to assist us in evaluating the request.

Our Commitment to Honoring Your Rights

Our Process for Responding to Requests for Access or Deletion under the CCPA

To respond to your request, we will ask you for certain pieces of Personal Information and endeavor to match those to information we maintain about you. The nature and number of verifying data elements we may request will depend on the nature of your request and the nature of the information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of our denial.

For requests for access, deletion, or correction, we will respond to your request or your authorized agent’s request in writing as soon as practicable and in any event generally not more than within 45 days after receipt of the request. We may extend this period to 90 days and, in the event that we do extend the period, we will explain to you or your authorized agent why we did so.

Authorized Agents

If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. If you would like to designate an agent to act on your behalf, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.

Non-Discrimination

If you exercise any of the rights explained in this Notice, we will continue to treat you fairly. If you exercise your rights under this Notice, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.

International Transfers

If you are located in a jurisdiction outside the United States, JPTC may disclose Personal Information collected from you to recipients located in countries outside of the jurisdiction in which you live, including JPTC’s service providers in the United States as well as outside of the United States. Such countries may not have data privacy laws equivalent to your home country.

By submitting your Personal Information to JPTC and the other recipients described in this Privacy Notice that are located in countries outside of your home country, each customer consents to the transfer of their Personal Information to JPTC and the other recipients described in this Privacy Notice. Customers may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Information Security

JPTC is committed to maintaining your trust and confidence. We employ reasonable information security policies and procedures based on recognized industry standards to protect your information, such as the use of physical, technical, and procedural controls in keeping with federal standards to safeguard Personal Information.

However, no security system is impenetrable. In addition, no transmission or electronic storage of information is guaranteed to be secure. JPTC thus underscores to customers that they should always use caution when transmitting information via the Internet. We encourage our customers to select strong and unique passwords that are not reused for other purposes, protect the confidentiality and security of their online passwords, and to immediately alert us to any concerns with your account or passwords.

Children’s Privacy

JPTC’s services are not intended for and are not directed to minors under the age of 13. We do not knowingly sell any Personal Information about children under 16 years of age.

Third Party Websites and Social Media Buttons

Our website may contain links to other third-party websites and social media buttons that connect to third party websites or applications with their own privacy policies. We are not responsible for the activities and practices that take place on these websites or applications. Accordingly, we recommend that you review the privacy policies posted on any website that you may access through our website.

Other Privacy Notices You May Receive From Us

This Privacy Notice supplements the information set out in the terms and conditions or other documents made available to you. However, for the avoidance of doubt, it is not intended to modify or override any representations made or commitments given by you (whether on your behalf or on behalf of others) in those documents.

Accessibility

JPTC is committed to ensuring that our communications are accessible to individuals with disabilities. Individuals with disabilities can access this Notice in alternative formats by contacting us at the address, phone, or email address below. This Privacy Notice is designed to meet content accessibility guidelines. To submit accessibility-related requests or report barriers to accessibility, please contact us at (603) 929-2700, information@jptc.com , Jordan Park Trust Company LLC, 60 Penhallow Street, Suite 400, Portsmouth, New Hampshire 03801.

Changes to this Notice

We may review and update this Notice from time to time. If changes are made, we will update the Privacy Notice and reflect the date of such modification in the date above. If the changes are material, you will be notified via a notice on our website.

Contact Us

If you have any further questions about our Privacy Notice or practices, please contact us at:

Jordan Park Trust Company LLC
60 Penhallow Street, Suite 400
Portsmouth, NH 03801
(603) 929-2700
information@jptc.com