Last Updated February 13, 2023
This privacy notice (“Privacy Notice”) describes how Jordan Park Trust Company LLC (“JPTC”) collects and processes Personal Information (defined below) in the course of conducting business, visiting our website, or applying for a job with us, 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 or independent contractors.
“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 client or household, including nonpublic personal information that JPTC obtains in connection with providing a service or financial product to such client such as information regarding a client’s account balance and investment activity.
This Privacy Notice applies to individuals (including, if applicable, their related entities to which JPTC, or an affiliate of JPTC, provides services), either as accountholders or in their capacity as authorized representatives of an entity or trust, as well as US visitors to our website. Throughout this Privacy Notice, “we,” “our,” or “us” refers to JPTC. For the purposes of European data protection laws, JPTC is the data controller of client Personal Information.
JPTC is committed to ensuring that our communications are accessible to individuals with disabilities. Individuals with disabilities can access this policy 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 or by email at email@example.com.
JPTC reserves the right to update this Privacy Notice from time to time, including for changes in the business, our data practices, or the law. JPTC will inform its clients of any changes by updating this Privacy Notice on our website, or otherwise as required by law.
If you decide to close your account(s) or become an inactive client, we will adhere to the privacy policies and practices as described in this Privacy Notice.
I. Personal Information We Collect
The Personal Information that we collect, including data collected in the past 12 months, includes the following:
- 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.
- Protected class information: Age, gender, gender identity or expression, race or ethnicity, veteran status, disability status (some of which is voluntarily provided during a job application process).
- 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.
- Educational information: Schools attended; graduation history; certificates received.
- Professional information: Current and former Job titles, employers, dates of employment, job history information, security industry registrations, Form U4 disclosures and information about disciplinary actions, LinkedIn profile link, and Jordan Park application history information.
- Inferences drawn from Personal Information collected.
II. Purposes for Collection of Personal Information
We use the Personal Information we collect to provide financial products and services to our clients, 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 clients, for information security and fraud detection, and to maintain our relationships and fulfill our obligations to our clients. We also may use Personal Information to process job applications and evaluate potential hires. We may also use your Personal Information to enforce or defend our rights, or those of another client or other third party.JPTC will collect and use Personal Information during business for tasks such as the execution of account documents for the legitimate interests of JPTC and to enable JPTC to comply with its legal and regulatory obligations.
Where JPTC or its agents require Personal Information to comply with BSA/AML policies or applicable legal requirements, failure to provide this information means JPTC may not be able to accept you as a client and may result in JPTC terminating its relationship with you.
We may use your Personal Information to contact you to tell you about products and services offered by us which we believe may interest you unless you advise us that you do not wish to receive marketing or market research communications from us. If you wish to stop receiving marketing or market research communications from us, you can contact us using the details provided at the bottom of the relevant marketing email.
JPTC will retain Personal Information for a minimum period of six years or for as long as required for us to perform the services, and as required by law. Regarding data we collect related to website usage, we will retain Personal Information only for as long as is relevant for the purposes for which it was collected. 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. We expect to delete Personal Information (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining that Personal Information.
III. How We Disclose Personal Information For Business Purposes
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 client or otherwise required or permitted by law for the following business and commercial purposes:
- Entering into account documents;
- Processing transactions and investments;
- Maintaining client records and providing centralized administrative and marketing services for current and prospective clients;
- 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;
- Complying with applicable BSA/AML policies and legal requirements;
- For employment and applicant evaluation purposes (if applying for a job through our website); and
- For other legal and regulatory obligations and reporting tax information to tax
The provision of Personal Information by a client may be necessary for JPTC to provide clients with the requested services, for the performance of any contractual relationship with that client, for us to comply with any legal or regulatory obligations, and for the other purposes as set out in this Privacy Notice where in JPTC’s legitimate interests. JPTC does not disclose any Personal Information it collects about its clients or former clients to anyone other than to its affiliates and certain service providers in connection with the administration, processing and servicing of client accounts or to its accountants, attorneys and auditors; as otherwise permitted or required by law, such as to respond to court orders and legal investigations or report to credit bureaus; or in the case of a merger, acquisition by another company, or sale of all or part of JPTC’s assets or during due diligence associated with a contemplated action. JPTC does not share Personal Information with unrelated third parties for those third parties’ own marketing purposes but may share Personal Information with affiliates to offer services to you that JPTC itself does not provide or to facilitate the provision of services by JPTC to you.
The following chart describes the categories of Personal Information 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, eligibility to work in the U.S. and visa status information.||Service providers that provide client relationship management; facilitate account management; process transactions and investments; maintain client records and provide centralized administrative and marketing services for clients; 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 in processing job applications and meeting related regulatory requirements; 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 client relationship management; facilitate account management; process transactions and investments; maintain client records and provide centralized administrative and marketing services for clients; 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.|
|Protected class information: Age, gender, gender identity or expression, race or ethnicity, veteran status, disability status.||Service providers that provide client relationship management; assist in processing job applications and meeting related regulatory requirements ; provide legal services.|
|Commercial information: Records of products or services purchased or considered, consuming histories or tendencies.||Service providers that provide client relationship management; provide advertising and marketing services.|
|Internet or other electronic network activity information: Device and browser type, browsing and search history on our Sites, and information regarding interaction with our Sites and our advertisements.||Service providers that provide data security services and cloud-based data storage; provide client relationship management; host our Sites and assist with other IT-related functions; provide website hosting, webcast and teleconference services; advertise and market our products; and provide analytics information.|
|Educational information: Schools attended; graduation history; certificates received.||Service providers that assist in processing job applications, and meeting related regulatory requirements.|
|Professional information: Current and former Job titles, employers, dates of employment, job history information, security industry registrations, , LinkedIn profile link, and Jordan Park application history information.||Service providers that assist in processing job applications, assist with background checks and 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 client relationship management; provide investment opportunity management.|
JPTC does not and will not sell Personal Information of clients or former clients and has not done so in the 12 months prior to the “Last Updated” date of this Privacy Notice.
IV. 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.
V. 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
- The categories of sources where JPTC collected the Personal
- The business or commercial purposes for which JPTC collected the Personal
- The specific pieces of Personal Information we collected about you.
- The categories of third parties with whom JPTC shared your Personal
- The categories of Personal Information that JPTC 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 receiving your request, JPTC will delete the Personal Information that JPTC has collected about you, except for situations when that information is necessary for JPTC to: provide you with a good or service that the client requested; perform a contract JPTC entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights set out in law. The law also permits JPTC 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 JPTC or that are reasonably aligned with expectations based on your relationship with JPTC. We will act on your deletion request within the timeframes set forth below.
To exercise the right to request the deletion of your Personal Information that JPTC collects or shares about you, contact JPTC at firstname.lastname@example.org or (603)929-2700. Requests for deletion of your Personal Information are generally free of charge. If your request relates to Personal Information we may have collected from or about you when you applied for a position with us, please submit your request by contacting the Jordan Park People Team at PeopleTeam@jordanpark.com or (415) 417-3000.
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 or deletion, 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, if we do extend the period, we will explain to you or your authorized agent why we did so.
If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and 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 New Hampshire law pertaining to powers of attorney.
If you exercise any of the rights explained in this Policy, we will continue to treat you fairly. If you exercise your rights under this Policy, 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.
VI. International Transfers
Ifyouarelocatedina jurisdiction outside of the United States,JPTCmaydisclosePersonalInformationcollectedfromyoutorecipients located in countries outside of the jurisdiction in which you live, including to JPTC’s service provider in the United States as well as outside of the United States. Such countries may not have data privacylawsequivalenttoyour home country.
By submitting your Personal Information to JPTC and the other recipients described in this Privacy Notice that are in countries outside of your home country, each client consents to the transfer of their Personal Information to JPTC and the other recipients described in this Privacy Notice. Clients may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
VII. 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,andproceduralcontrolsinkeepingwithfederalstandardstosafeguardPersonal 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 clients that they should always use caution when transmitting information via the Internet, 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. Please always use caution when transmitting information over the Internet, use strong and unique passwords that you do not also use on other online services, and notify us immediately of any concerns with your account or passwords.
VIII. 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 collect or store any Personal Information about children under 16 years of age without parental consent.
IX. Third Party Websites
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.
X. Important Information
This Privacy Notice supplements the information set out in the subscription 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.
XI. 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