Scope. Provider utilizes the System to provide certain investment management, investor reporting, and communication services to you (the “Services”). In the course of providing the Services, Provider may collect “Personal Information,” which means any information relating to an identified or identifiable natural person (a “data subject”) (an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).
Changes to this Policy. Provider reserves the right to update this Policy from time to time by posting a new Policy on this page, and in some cases where changes are material Provider may also contact you via electronic mail or post a notice on the homepage to let you know of such changes. You are advised to consult this Policy regularly for any changes. Your continued use of the System after such changes have been made constitutes acceptance of those changes.
Collection of Information:
Information that You Provide. Provider collects any information that you voluntarily provide, including when you create an account on the System or when you use the Services available through the System. Information that you may provide includes your email address, name, phone number, location, and online social accounts. Provider may also collect information that you provide by electronic mail, telephone or other means.
Automatically Collected Information. Provider may automatically collect certain technical information from your computer or mobile device when you use the System, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the System, the pages you view immediately before and after you access the System, and the search terms you enter on the System. This information allows Provider to recognize you and personalize your experience if you return to the System using the same computer or mobile device, and to improve the System and the Services.
Cross-Site Tracking. Provider does not utilize technical measures in the System to track your activities across different web sites or online services, whether you configure your browser’s Do Not Track feature or otherwis The System does utilize third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that utilize those interfaces.
Reviewing and Correcting Information. You may update or correct contact information and other Personal Information stored about you on the System by accessing your account/profile page, or by sending a written request to the Provider.
Use and Disclosure of Information. Provider may collect, use, share, and otherwise process your personal information for a number of purposes, including, but not limited to:
Service Providers. Provider engages third-party service providers (such as payment processors, hosting providers and analytics and security providers) to assist in operating and marketing the System. Provider’s engagement of third-party service providers is often necessary for Provider to provide the Services to you, particularly where such third-party service providers ensure that the System and Services are operating and secure. In other cases, Provider has a legitimate interest in third-party service providers that can help improve the System and the Service.
Other Disclosure. Provider may disclose Personal Information about you to others: (a) with your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of the terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. Provider may also transfer your Personal Information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, acquisition or sale, joint venture, assignment, transfer or other disposition of all or any portion of Provider’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that Provider transfer Personal Information to will not be permitted to process your Personal Information other than as described in this Policy without providing you notice and, if required by applicable laws, obtaining your consent.
Marketing. If you submit your information to a Provider via Juniper Square, Provider may provide you with information about the System, Services or required notices. In addition, Provider may use collected information for delivering marketing communications that may be of interest to you. You have the right to ask Provider not to process your Personal Information for marketing purposes.
Jurisdiction. Information collected through the System will be stored in, processed in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the System, you consent to such transfer to, storage in and processing within the United States.
Security. Provider is committed to protecting your information from unauthorized access, use or disclosure. The system and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the System. For example, all information you transmit to the System is encrypted using Transport Layer Security technology (TLS). However, no information or communication system can be 100% secure, so Provider cannot guarantee the absolute security of your information. In addition, Provider is not responsible for the security of information that you transmit to the System over networks that Provider does not control, including the Internet and wireless networks.
Retention. Provider will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. If you wish to access or correct any information Provider holds about you, you may have your data deleted, blocked or corrected (as long as compliant with applicable law). Provider also collects and retains information through the System in an anonymized form, i.e. tracking the pages you visit and how long was spent on each page.
To enable and support security features, prevent fraud, and protect your data from unauthorized access.
To enable features and help us provide you with personalized content.
To analyze how you use the System and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the System.
Third-Party Cookies. Provider uses the following third-party Cookies on the System:
DocuSign (if applicable). The System provides the option to execute agreements via DocuSign. If you interact with DocuSign via the System, you may encounter cookies used by DocuSign in their internal operations. Seehttps://www.docusign.com/company/privacy-policy for details.
Zendesk. Provider provides help materials via an integration with Zendesk. When you use the help center, you may encounter cookies used by Zendesk in their internal operations. See https://www.zendesk.com/company/customers-partners/privacy-policy/ for details.
Opting Out. You can control and/or delete cookies as you wish – for details, see https://www.aboutcookies.org/. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being place If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by Provider.
a. If you are a resident of the European Union, Provider will process your Personal Information in compliance with the EU General Data Protection Regulation (“GDPR”). For information submitted using the System, Provider is the data controller, as defined under GDPR. In accordance with GDPR, as a data subject you will be accorded with any applicable rights, which may include the following:
i. right of confirmation;
ii. right of access;
iii. right to rectification;
iv. right to erasure;
v. right of restriction of processing;
vi. right to data portability;
vii. right to object;
viii. right to withdraw data protection consent; and
ix. the right to lodge a complaint with a supervisory authority.
b. Third-Party Websites. The System and communications from Provider may contain links to websites operated by third parties. You acknowledge and agree that Provider is not responsible for the collection and use of your information by such websites that are not under Provider’s control. Provider encourages you to review the privacy policies of each website you visit.
c. Children’s Information. The System is not directed to, nor does Provider knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided information without your consent, please contact Provider immediately using the contact information provided below.
d. Other Agreements. You may from time to time enter into binding legal agreements relating to certain Services available through the System, which may have terms that are different from those of this Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.
Role of Juniper Square:
b. Business Transfer. If Juniper Square, or substantially all of Juniper Square’s assets, are acquired, or in the unlikely event that Juniper Square were to go out of business or enter bankruptcy, user information will be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Juniper Square may continue to use your Personal Information as set forth in this Policy (as it may be amended from time to time).
c. Contact Information. If you have any questions about this Policy or the collection or use of information about you, please write to Provider at email@example.com.