To Our Clients:
Protecting the privacy of your information is nothing new to us. We have in the past and will continue in the future to protect your right to privacy. As a general rule, we do not disclose nonpublic personal information about our clients or former clients to anyone that is not affiliated with us without the client’s consent.
Types of “Nonpublic Personal Information” We Collect
In the course of our investment activities on your behalf, we may collect nonpublic personal information from you, such as your name and social security number, from documents that you deliver to us or from our discussions with you.
Persons to Whom We Disclose Information
As stated previously, we generally do not disclose any nonpublic personal information about our current or former clients that we obtain during the course of our relationship to unaffiliated third parties, except as permitted by law. However, in order to conduct investment activities on your behalf, in limited situations we may need to disclose this nonpublic personal information to unrelated third parties (for example, third party managers, auditors, qualified custodians or the Internal Revenue Service). Also, in some situations, we may need to disclose or share nonpublic personal information with an affiliated third party, such as certain entities that provide back office support to us, in order to conduct investment activities on your behalf. Your authorization for us to conduct investment activities on your behalf and your continuing relationship with us acts as your consent to our disclosure of your nonpublic personal information when such disclosure is necessary to conduct such activities.
In addition, we restrict access to nonpublic personal information to our employees who need to know the information. Your nonpublic personal information may also be shared with our attorneys, accountants, third party service providers and auditors. In all such situations, we take steps necessary to ensure that the confidential nature of the information being shared is maintained.
Protecting the Confidentiality and Security of Current and Former Clients’ Information
In order to protect your information, we also maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
If you have any questions about our privacy policies, please contact Adán D. Araujo, our Chief Compliance Officer at 817-333-0027, because your privacy and the confidentiality of your information are very important to us.
Additional Information for California Residents
The California Consumer Privacy Act (“CCPA”) is a sweeping piece of legislation that grants California residents increased control over their personal data.
The CCPA allows consumers to find out what personal information of theirs has been gathered, to request that businesses delete their data, to opt out of having their information sold, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to assure that their vendors comply as well.
This privacy notice provides the details you need to understand your rights under the CCPA, and to exercise those rights. It provides you with the contact information you need to take action regarding the privacy of your data.
Your PII Rights
The CCPA provides you with certain rights in regard to what we do with your personally identifiable information (“PII”). This section details those rights, how to exercise them, and what Jasper Ridge will do in response.
You have the right to request that we disclose to you, free of charge, the categories and specifics of the PII we collect about you and/or, otherwise disclose about you to a third party for business purposes. We require a verifiable request from you to ensure that it is, in fact, you who is requesting such a PII disclosure. Once we verify the request, we will provide that information to you.
Your request for disclosure can apply to any PII we collect about you for as long as twelve months preceding your request. We are not required to disclose information about the PII we collect about you more than twice in a twelve-month period.
Following our verification of your request, we will disclose to you, unless otherwise restricted by law or regulation, the following PII we collect about you:
- The categories of personal information we have collected about you
- The categories of sources from which the personal information is collected
- The business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom we share personal information
- The specific pieces of personal information we have collected about you
Following our verification of your request, we will disclose to you, unless otherwise restricted by law or regulation, the following PII about you that we sell to a third party or otherwise disclose for business purposes:
- The categories of personal information we have collected about you that we disclose
- The categories of sources from which that personal information is collected
- The business purpose for collecting, and/or disclosing that personal information
Jasper Ridge does not sell client information to third parties at the current time. Should this change in the future, Jasper Ridge would adopt policies and procedures to comply with legal and regulatory requirements, including providing the ability to opt-out of these practices.
Deletion of PII
You have the right to request that we delete PII we have collected from you. Following our verification of your request, we will comply with your request and delete any or all of your PII in our possession that we collected from you and/or any or all such PII in the possession of our service providers, unless otherwise restricted by law or regulation. Specifically, Jasper Ridge may be limited in its ability to delete certain PII since, as an SEC-registered investment adviser, it is required by securities laws and regulations to maintain certain information for extended periods of time. To the extent Jasper Ridge is not required to maintain certain PII, it will honor requests for deletion of such information.
Non-Discrimination for Exercising Your PII Rights
We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.
Contacting Us to Exercise Your PII Rights
You may contact us in order to exercise any of your rights set forth in this privacy notice by calling this toll-free number, 1-800-470-5808, emailing us at firstname.lastname@example.org, or visiting our website https://www.jasperridge.com/.