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 of 2018, California Civil Code Sections 1798.100 et seq. (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), provides additional rights to California residents with respect to their Personal Information (as defined below). This “Additional Information for California Residents” notice (“Notice”) is intended to provide California Residents information regarding these rights.
The CCPA applies to “Personal Information.” Personal Information, as defined by the CCPA, refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person or household. Examples of the categories of Personal Information we collect about you include your name, address, e-mail address, telephone number, financial information, and professional or employment-related information. Information that is public, aggregated, de-identified, anonymized, or otherwise subject to exception under applicable law is not considered Personal Information. Further, the CCPA does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act.
Additional Rights for California Residents
As noted above, the CCPA provides you, as a California resident, additional rights with respect to your Personal Information. These rights are summarized below (subject to exemption under applicable law):
Right to Know: The CCPA gives you the right to know what Personal Information we are collecting and how that information is being used. This means that we must (1) inform you in advance regarding our data collection, and (2) respond to your requests to know what has been collected.
With respect to the second requirement, you can submit a request related to what Personal Information we have collected from you, including the following:
- 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 your Personal Information;
- The categories of third parties with whom we share Personal Information; and
- The specific pieces of Personal Information that we have collected about you.
When you submit a verifiable request, we will provide the requested information for up to a 12-month period preceding the request. Such information will be provided to you free of charge; however, please keep in mind that you may submit requests no more than twice in a 12-month period.
Right to Delete: You have the right to request that we delete Personal Information we have collected from you. We will comply with your request and delete any or all of your Personal Information in our possession that we collected from you and/or tell our service providers to do the same, unless otherwise restricted by applicable law. Specifically, JRP may be limited in its ability to delete certain Personal Information since, as an SEC-registered investment adviser, it is required by securities laws and regulations to maintain this information for defined periods of time. To the extent JRP is not required to maintain the Personal Information, it will honor requests for deletion of such information.
Right to Correct: You have a right to correct inaccurate or obsolete Personal Information that we may maintain.
Right to Opt-out of the Sale or Sharing of Personal Information: You have the right to opt-out of the “sale” of your Personal Information (i.e., disclosure of Personal Information to third parties for valuable consideration), or “sharing” of your Personal Information (i.e., disclosure of Personal Information to third parties for cross-context behavioral advertising). However, this right to opt-out of certain sales or sharing of your Personal Information is not applicable because we do not sell your Personal Information to third parties for valuable consideration or share your Personal Information for cross-context behavioral advertising. As such, we do not need to provide you an opt-out.
Right to Limit the Use and Disclosure of Sensitive Personal Information: You have a right to limit the use and disclosure of your sensitive personal information (e.g., your social security number, financial account information, etc.). We collect and use sensitive personal information to provide you with services. We do not sell your sensitive personal information, or share your sensitive personal information other than as permitted or required by applicable law. As such, we do not need to provide you a right to limit.
Right to No-Retaliation: We will not retaliate or discriminate against any person based on their exercising any of their rights afforded by the CCPA. California Residents may exercise their rights, as discussed above, by submitting a verifiable request to us by calling 1-800-470-5808 (toll-free) or emailing firstname.lastname@example.org.
The CCPA requires that we disclose the criteria used to determine the length of time that we retain your Personal Information. The length of time that we hold your Personal Information and other information will vary and will be determined based on:
- Any legal obligations we have to retain the information, including those arising from legal requirements in applicable securities regulations, or for our own legal purposes (such as enforcing our agreements or litigation);
- Our relationship with you, including the status of your relationship with us;
- The purpose for which we are using your information - we will need to keep the information for as long as is necessary for that purpose
- Your requests related to your information or otherwise; and
- Technical considerations and feasibility, and level of protections in place for your information.