Effective Date: March 17, 2020
Collection of Investor Information. JGC collects nonpublic personal information about Investors primarily from the information the JGC receives in subscription documents, investor questionnaires and other forms submitted by Investors in writing, in person, by telephone, electronically, or by any other means. This information includes name, address, nationality, employment information and financial/investment qualifications. JGC may also collect information from Investor transactions with JGC and/or its affiliates including account balances, investments, withdrawals/redemptions and fees or through other interactions with JGC either written or oral, for example communications with JGC staff.
Disclosure of Non-Public Personal Information. JGC does not disclose any non-public personal Investor information about Investors or former Investors with non-affiliated third parties, except as necessary to its affiliates, and except as permitted by law, such as information that JGC provides to its administrator, prime brokers, joint marketers, outside accountants and attorneys who agree to limit their use of such information in order to service the investments in the Funds (collectively, “Service Providers”).
Except as described above, JGC will not disclose non-public personal Investor information to non-affiliated parties, unless an Investor has been provided a notice of the possibility of such disclosure and an opportunity to “opt-out” of the disclosure.
Information Safeguarding. JGC restricts access to non-public personal information about Investors to those employees and Service Providers who need to utilize that information to enable JGC to provide its services to Investors. JGC maintains physical, electronic and procedural safeguards that comply with federal standards to safeguard Investors’ non-public information.
California Collection Notice. If you are a California resident, California law requires us to provide you with some additional information regarding how JGC collects, uses, and shares your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). Please note the CCPA’s scope excludes personal information covered by certain financial services-specific privacy laws, including the Gramm-Leach-Bliley Act (GLBA) and California Financial Information Privacy Act (FIPA). Our separate Privacy Notice that is provided to investors applies to this excluded data and has been provided to our fund investors.
When you submit information to us through our webform at https://www.jgoldmanlp.com/contact, we may collect the following categories of information from you, in addition to the information we collect in connection with providing financial products and services:
- Identifiers (such as your name, contact information, IP address); and
- Any information you provide us in the webform comment field.
This information may be disclosed as described in the “Disclosure of Non-Public Personal Information” section of the privacy notice, above. JGC may use this information for the following purposes:
- Legal and everyday business purposes: Your personal information may be processed for our everyday business purposes, such as to answer your inquiries or communicate with you about employment opportunities.
- With your authorization or for other purposes permitted by law: Your personal information may be shared with or processed by certain persons with your consent, upon your instruction, or for any other purposes permitted by applicable law (including to comply with subpoenas and other valid legal process).
Your California Privacy Rights. If you are a California resident, you may have certain rights. California law may permit you to request that we:
- Provide you with the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
- Provide you with access to and/or a copy of certain personal information we hold about you.
- Delete certain personal information we have about you.
You may have the right to receive information about the financial incentives that we offer to you for your personal information (if any). You also have the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we may need certain information to provide services to you or for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use some of our services.
Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
If you would like further information regarding your legal rights under California law or would like to exercise any of them, please visit our contact form or call us at 212-262-4990. You will need to provide additional information to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
Additional Information for California Residents. Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months.
The examples contained in this policy are illustrations and are not intended to be exclusive. This policy complies with recently enacted federal law regarding privacy. You may have additional rights under other foreign or domestic laws which may apply to you.
Please contact JGC at 212-262-4990 or via our contact form with any questions or comments regarding this policy, or any related matter.