Privacy

Privacy Notice

Last Updated March 2 2021

Financial institutions like Jordan Park Trust Company LLC (“JPTC”) are required to provide privacy policy notices (“Privacy Notice”) to their clients. JPTC believes that protecting the privacy of client Personal Information (“Personal Information”) is of the utmost importance.

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 describes the collection, protection and sharing of Personal Information of JPTC’s clients, prospective clients, and former clients. These policies apply 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 visitors to our website and certain employee or applicant data. 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 information@jptc.com.

This Privacy Notice is given to new clients upon entering into an agreement for JPTC’s products or services and is distributed to all existing clients on an annual basis, or promptly thereafter in the event of substantive changes to our privacy policies. This Privacy Notice is reviewed on an annual basis, and JPTC reserves the right to update this Privacy Notice from time to time, including for changes in the businesses, 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

In the year prior to the date this Privacy Notice was issued, the Personal Information that we collected about our clients included name, address, telephone number, email address, social security number, birth date, tax identification number, state or country of tax residence(s), assets, income, employment history, investment experience and identification documents for Bank Secrecy Act anti-money laundering (“BSA/AML”) legal requirements that may have been received in account documents and related forms. We also may collect financial or other information such as account activity, investment activity and financial goals, and account balances related to a client’s transactions with JPTC, its affiliates (as may be applicable), or others, together with any other Personal Information required by applicable laws. We may collect personal information related to employee or applicant qualifications and work experience. Finally, we may collect technical information about your use of our website, including IP addresses and device identifiers.

We may collect Personal Information about our clients from different sources, including directly from our clients, as well as from third parties, including other financial institutions or referral sources. We may also automatically collect information using cookies and other tracking technologies. JPTC does not respond to web browser “do not track” signals.

We use each of the categories of the Personal Information we collect to provide financial products and services to our customers, to market to existing and prospective customers, for information security and fraud detection, and for employment purposes with regard to employee or applicant data. 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 to comply with its legal and regulatory obligations. Where JPTC or its agents requires 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.

JPTC will retain Personal Information for a minimum period of six years or for as long as required for us to perform the services, comply with applicable legal or regulatory obligations or for any other legitimate business reason.

II. How We May Share 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 business and commercial purposes:

  • (i) Entering into account documents;
  • (ii) Processing transactions and investments;
  • (iii) Maintaining client records and providing centralized administrative and
    marketing services for current and prospective clients;
  • (iv) Investigating and resolving complaints and recording calls and managing litigation;
  • (v) Monitoring electronic communications and other IT systems for data security incidents, fraud or crime detection or for regulatory reasons;
  • (vi) Complying with applicable BSA/AML policies and legal requirements;
  • (vii) For employment and applicant evaluation purposes; and
  • (viii) For other legal and regulatory obligations and reporting tax information to tax authorities.

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. 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.

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.

III. Your Privacy Rights

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. In addition, this section of our Privacy Notice is not applicable to personal information processed solely in the business-to-business context, for instance, information about an individual acting in his or her capacity as a representative of a company, and other data that is exempt from the requirements of the CCPA.

If you are located in the European Economic Area (“EEA”), you have a right to object to the processing of your Personal Information where that processing is carried out for JPTC’s legitimate interest.

Requests for Household Information

Please note that certain types of Personal Information may be associated with a household, meaning a group of people living together in a single home. Each member of the household must make requests for access or deletion of household Personal Information. We will then verify each member of the household using verification criteria. If we are unable to verify the identity of each household member to the degree of required certainty, we will not be able to respond to the request. We will notify you to explain the basis of our denial.

Your Right to 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 which JPTC collected the Personal
    Information.
  • The specific pieces of information we collected.
  • The third parties with whom JPTC shared the information.
  • 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. To exercise the right to request the disclosure of Personal Information that JPTC collects or shares about you, contact JPTC at information@jptc.com or (603) 929-2700. Requests are typically free of charge.

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

Upon receiving and verifying such 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; comply with or exercise rights set out in law; or use the information internally 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 the your relationship with JPTC.

To exercise the right to request the deletion of your Personal Information, contact JPTC at information@jptc.com or (603) 929-2700. Requests for deletion of your Personal Information are generally free of charge.

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.

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 comply with our agent verification process.

For requests for access or deletion, we will respond to your request or your authorized agent’s request in writing, or verbally if requested, 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.

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.

Non-Discrimination

You have a right not to be discriminated against for the exercise of the privacy rights conferred by the CCPA.

IV. International Transfers

If you are located in the EEA, JPTC may disclose Personal Information collected from you to recipients located in countries outside of the EEA, including to the United States, which may not have data privacy laws equivalent to those in the EEA. By submitting your Personal Information to JPTC and the other recipients described in this Privacy Notice that are located in countries outside of the EEA, each client consents to the transfer of their Personal Information to JPTC and the other recipients described in this Privacy Notice that are located in countries outside of the EEA. 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.

Individuals in the EEA have certain data subject rights which may be subject to limitations and/or restrictions. These rights may include the right to: (i) request access to and rectification or erasure of their Personal Information; (ii) obtain restriction of processing or to object to processing of their Personal Information; and (iii) the right to ask for a copy of their Personal Information to be provided to them, or a third party, in a digital form. If you are located in the EEA and wish to exercise any of these rights, you should contact JPTC. Individuals in the EEA also have the right to lodge a complaint about the processing of their Personal Information with their local data protection authority.

V. Information Security

JPTC is committed to maintaining your trust and confidence. JPTC restricts access to Personal Information it collects about its clients to its personnel who need to know that information to provide products or services to clients. 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 its clients’ Personal Information. JPTC employees are also trained regarding the appropriate handling of client 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 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.

VI. Children’s Privacy

JPTC’s services are not intended for and are not directed to children. We do not knowingly collect or store any Personal Information about children under 16 years of age without parental consent.

VII. Contact Us

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

Jordan Park Trust Company LLC
One Liberty Lane East
Hampton
NH 03842
(603) 929-2700
information@jptc.com