In this policy, the terms “we”, “us”, “our”, and “ours” refer to JCAP Topco, LLC (“JCAP”) and its affiliates. Sections 4-7 apply to JCAP affiliates designated in Section 4 and to information processed on accounts established in the European Economic Area. (EEA). All other sections of this policy apply to JCAP and all affiliates.
JCAP respects individual privacy and values the confidence of its customers, employees, consumers, business partners, and others. Not only does JCAP strive to collect, use, and disclose Personal Information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices. We have therefore adopted a privacy and data protection policy that is applicable to information relating to our employees as well as to information relating to other individuals collected or processed in the general course of our business, including but not limited to Personal Information received from locations within the European Union.
This Policy applies to any Personal Information received by JCAP in any format, including electronic, paper or verbal.
For purposes of this Policy, the following definitions shall apply:
The following company affiliates adhere to the Privacy Shield Principles and may collect the same types of EU data as JCAP:
Where JCAP collects Personal data directly from individuals in the EEA, we will inform them of the following:
To ensure fair and transparent processing of personal data JCAP will also provide the following information:
Where the personal data was not obtained from the data subject, the following information will be supplied in addition to the information set out above:
Where JCAP intends to further process the personal data for a purpose other than that for which the personal data were obtained JCAP shall provide the data subject prior to that further processing with information on that other purpose.
Where JCAP receives Personal Information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.
JCAP will offer the opportunity to choose whether their Personal Information is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. JCAP will provide clear and informed methods to exercise their choices.
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, JCAP is potentially liable. JCAP will obtain assurances from its Agents that they will safeguard Personal Information consistently with this Policy. Examples of appropriate assurances that may be provided by Agents include: a contract obligating the Agent to provide at least the same level of protection as is required by the relevant Privacy Shield Principles, Privacy Shield certification by the Agent, or being subject to another European Commission adequacy finding. Where JCAP has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy, JCAP will take reasonable steps to prevent or stop the use or disclosure.
Upon request, JCAP will grant reasonable access to Personal Information that it holds. In addition, JCAP will take reasonable steps to permit Consumers and Employees to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
JCAP will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to Personal Information to employees who need to know that information to provide services. We maintain physical, electronic and procedural safeguards that comply with applicable laws to guard Personal Information.
JCAP will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. JCAP will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.
JCAP is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Any Employee that JCAP determines is in violation of this policy may be subject to disciplinary action up to and including termination of employment.
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JCAP has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Adherence by JCAP to these Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Information that allows us to configure the services we provide so that they are more easily provided to you. Examples may include your IP address, browser type, referring/exit pages, operating system, affiliate id, etc. Technical information does not identify you personally, but it may when associated with other information.
We may collect non-public personal information about you as permitted by law from:
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query via email to Privacy@JCap.com. If requested to remove data, we will respond within a reasonable timeframe or within the General Data Protection Regulation timeframes for personal data stored in the UK.
We make every effort to follow industry standard security measures to prevent the loss, misuse and alteration of the information under our control. However, no information transmitted on the internet or stored on servers is 100% secure. Fraudulent people exist, software and hardware can malfunction, and people make mistakes. As a result, we cannot guarantee that any information covered by this Policy will be absolutely secure.
At this time, we do not respond to “do not track” signals sent from browsers.
If you have questions regarding this Policy or about the privacy practices of JCAP, please contact us at: Privacy@JCap.com.
EFFECTIVE DATE: April 2018