Effective Date: May 21st, 2018
Your privacy and trust are important to us and this Privacy Statement (“Statement”) provides important information about how Juniper Place Investor Intelligence Limited and GFP Juniper LLP, (together “Juniper Place,” “we,” “us” or “our”) handle personal information. This Statement applies to any Juniper Place website, application, product, software, or service that links to it (collectively, our “Services”).
Please read this Statement carefully and contact our Data Protection Officer if you have any questions about our privacy practices or your personal information choices. Our Data Protection Officer can be contacted at email@example.com.
It is important that you check back often for updates to this Statement. If we make changes we consider to be important, we will let you know by placing a notice on the relevant Services and/or contact you using other methods such as email.
About Juniper Place
We are a leading global placement firm and provider of institutional investor intelligence to alternative asset managers and institutional investors. We provide a variety of services to these clients and other parties, including, but not limited to:
- Introductions, marketing and capital raising for our clients to institutional investors;
- Research and analysis of institutional investors focusing on their alternative asset class investment preferences;
- Advisory and consultancy services; (collectively, and among others, our “Services”).
Juniper Place is committed to the responsible handling and protection of personal information. Personal Information means any information that either
- personally identifies a natural person; or
- pertains to an identifiable natural person, i.e. someone 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 his or her physical, physiological, genetic, mental, economic, cultural or social identity; or
- constitutes individually identifiable information about an individual collected by us online through this website and that we maintain in an accessible form; or
- we are otherwise required to protect under applicable data privacy laws (including, but not limited to, national, international and supranational data protection and privacy laws, directives, regulations and comparable legal acts).
We collect, use, disclose, transfer, and store personal information when needed to provide our Services and for our operational and business purposes as described in this Statement. We want to be clear about our privacy practices so that you can make informed choices about the use of your information, and we encourage you to contact us at any time with questions or concerns.
Personal information we collect
We collect personal information from you, for example, if you request information, purchase or use our Services, or request customer support. Examples of Personal Information include your contact details such as your name, email address or phone number as well as information about your relevant professional education and experience, skills, preferences, membership in professional organisations.
Not all of the personal information we hold about you will always come directly from you. It may, for example, come from your employer, other organisations to which you belong. We also collect personal information from third parties such as publicly available websites, our partners and service providers. This is undertaken in order to help us maintain data accuracy so that we can offer Services and products we think may be of interest to you and the firm that you represent. Our technology and servers also automatically collect information about you and the organisation that you represent in order for us to analyse usage and improve your experience.
We share personal information with others only as described in this Statement, or when we believe that the law permits or requires it.
Occasionally we collect and process what may be considered sensitive personal information. Sensitive personal information means personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. In some instances, sensitive personal information may also include criminal allegations or convictions, precise geolocation information, financial and bank account numbers, or unique identifiers such as government-issued social security numbers, driver’s license, and passport numbers. An example of when this might occur is when you purchase or use our services, in which case, will collect payment information, such as financial information, and other information necessary for us to process the service. Some of our Services will ask you to share your precise geolocation so we can ensure that we meet any regulatory obligations, such as those required in the UK by the Financial Conduct Authority, or other global regulators, and also to customise your experience and increase the accuracy of the Service. We may also collect information such as a government-issued identification number if you use our Services to apply for employment. Information that is considered sensitive under applicable law will be handled in accordance with such laws.
How we use personal information
We process personal information for the Service and other legitimate business purposes. This may include:
- Account Administration: Establishing your account with us where we will require your name, business email address, business phone number and information about your device.
- Marketing and Events: We and where appropriate, our subscribing customers, use personal information to deliver information about our clients Alternative Asset Class marketing and event communications to you via email, telephone and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. Even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts.
- Tailored Content: We use personal information to deliver and suggest content such as news, reports, and business information and to personalize your experience with our Services. Some of our Services will ask you to share your precise geolocation so we can customize your experience, ensure that we are meeting our legal and regulatory obligations, such as those required in the UK by the Financial Conduct Authority and increase the accuracy of the Service. If you agree to share your precise geolocation with us, you will be able to turn it off at any time by going to the privacy settings on your mobile device or online.
- Hosted Services Information: Some of our Services provide data and document storage as an integral part of the product or solution offering. Documents and data stored by our customers may contain personal information in business and
personal tax forms, and legal and litigation-related documents. Any information stored by or on behalf of our customers is controlled and managed by and only made accessible to those customers or others our customers may authorise from time to time. Our access to this information is limited to Juniper Place personnel and if relevant, our customer whose products we are marketing.
- Legal Obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our audit requirements and as we otherwise believe to be necessary or appropriate:
- under applicable law, which may include laws outside your country of residence;
- to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence;
- to enforce our terms and conditions; and
- to protect our rights, privacy, safety, or property, or those of other persons.
- Where you request information from us and if the service requires you to provide a geolocation, then it is your responsibility to provide correct and accurate information.
- Community Forums, Including Chat Rooms, Surveys and Polls. Our Services may provide features including chat rooms, messaging services, community and event forums for collaboration, peer connection and information exchange. Depending upon the Service, the personal information you choose to post, share, upload, or make available may be public and visible to others who use those Services. You should never post or share any information that is confidential or about others unless you have permission to do so. We may use information you provide in community and event profiles and forums to personalize your experience and to make content and peer connection recommendations.
Sharing personal information
Juniper Place shares or discloses personal information when necessary to provide Services or conduct our business operations as described below. When we share personal information, we do so in accordance with data privacy and security requirements. We may also share aggregated, non-personal, anonymized, and statistical data with third parties. Below are the parties with whom we may share personal information:
- Within Juniper Place globally if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development. All of our employees, agents and contractors are required to follow our data privacy and security policies when handling personal information.
- With our business partners to deliver Services, provide content, or to host conference and events.
- With third-party service providers when necessary to fulfil the services they provide to us, such as software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; payroll and transactional Services. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us.
- With third parties who subscribe to our service. We share your business-related information with Alternative Asset Class Fund Managers and Service providers that subscribe to our Services. Examples include Hedge Fund, Private Equity, Real Estate, Infrastructure, Private Debt or Prime Brokers. The third parties may contact you about their Alternative Fund Management products and services that may be relevant to you.
- With third parties for legal reasons when we believe it is required, such as:
- To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence.
- In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
- To protect our rights, users, systems, and Services.
- With recruitment and human resource management partners. If you register with us in order to apply for employment, your personal information, including any sensitive personal information you provide, will be made available to the appropriate staff within our organisation and externally in order to support us. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us. Internally, all of our employees, agents and contractors are required to follow our data privacy and security policies when handling personal information.
Storing and processing personal information
Juniper Place is a European organisation with representation and affiliates globally. As such, your personal information may be stored and processed outside of your home country. We take steps to ensure that the information we collect is processed according to this Privacy Statement and the requirements of applicable law wherever the data is located.
- Storing of Personal Information: Juniper Place utilises the networks, databases, servers, systems, support, and help desks provided by third parties such as cloud hosting services, and technology suppliers, to serve the needs of our business, workforce, and customers. The third-party services providers include, but are not limited to Microsoft Ireland Operations Ltd, Rackspace International GmbH, Switzerland, KPMG LLP, United Kingdom, Enable IT Technologies Ltd, United Kingdom, Signal & Noise Limited, United Kingdom.
- Processing of Personal Information: We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within Juniper Place or to third parties in areas outside of your home country. The areas in which these recipients are located will vary from time to time, but may include the United States, Europe, Asia, Australia, and other countries or regions where Juniper Place, its subscribing customers or its affiliate network is located.
When we transfer personal information from the European Economic Area to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. In other words, your rights and protections remain with your data. For example, we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed
to ensure that the recipients of your personal information protect it.
Cookies and similar technologies
What is a cookie?
Cookies are small data files that many internet sites automatically download to a user’s computer, phone or tablet’s hard disk. They are primarily used in helping web sites recognise a user that has visited the web site previously such as simplifying the logging on process for registered users. They can store account and password information. Most web browsers automatically accept cookies.
For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org.
As part of your registration to use our site you confirm that you accept that cookies will be used by this site and will be used to collect information for the purposes described below.
What cookies will our site use and for what purposes?
Our site uses a number of different cookies:
- “Remember me” / user preference cookies.These cookies enable our site to remember your personal preferences such as log in details and other user preferences in order to improve the user experience for example by avoiding you having to re-enter these details on each visit to our site. Depending on your user preferences these cookies will either be single session cookies (ie they capture information only in respect of the browser session) or persistent cookies (ie they caputre information each time you use the site across different browser sessions).
- Analytics cookies. We use both session and persistent cookies to collect information such as number of visitors to the site
and pages visited in order to analyse user behaviour. This information is collected in an anonymous form and will be collated with similar information received from other users to enable us to compile reports in order to develop and improve user experience on our web site
How long will the cookies remain on my computer?
The cookies will remain in the cookies file of your browser after the closing of the browser, and will become active again
when our site is reopened, until removed. The cookie(s) can be deleted at any time by you. The cookie(s) will not collect any
information when you are not accessing our site.
Third party cookies
We use Google Analytics and Wistia Analytics cookies to help us analyse the use of our site. Google Analytics generates
statistical and other information about website use by means of cookies, which are stored by users’ web browsers on their
computer. Wistia Analytics is used by us to track users’ viewings of video content on our site. The information generated
relating to our website is used to create reports about the use of the website and its content.
- Internet Explorer: https://privacy.microsoft.com/en-us/internet-explorer-ie11-preview-privacy-statement
- Chrome: https://www.google.com/intl/en/chrome/browser/privacy/
- Firefox: https://support.mozilla.org/en-US/products/firefox/protect-your-privacy
- Safari: http://www.apple.com/privacy/manage-your-privacy/
However, please be aware that this might render certain functions of our Site inoperable or more difficult to use. Depending on the Internet browser you use, you might also be able to specifically reject third-party cookies. In this context, please note, however, that third parties might still have access to your Personal Information to the extent that such information is logged by first-party cookies.
Other Tracking Technologies
- Local shared objects/Flash cookies: Flash cookies, also known as local shared objects, are designed to support browser content supported by Adobe® Flash. They are usually used to enable ads and video content on websites. Like other cookies, they will store information on your device, some of which will be specific to the Flash-enabled content. Flash cookies can only be deleted within Adobe Flash rather than via your browser. For more information on how to do so in the settings please see the following information: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.
- Web server & application logs: Our servers automatically collect certain information to help us administer and protect the Services, analyse usage, and improve users’ experience. The information collected includes:
- IP address and browser type
- Device information
- Device operating system and other technical facts
- The city, state, and country from which you access our website
- Pages visited, and content viewed, stored, and purchased
- Information or text entered
- Links and buttons clicked
Do Not Track
Some browsers transmit Do Not Track signals to websites. Due to the lack of a common interpretation of Do Not Track signals throughout the industry, Juniper Place does not currently alter, change, or respond to Do Not Track requests or
signals from these browsers. We will continue to monitor industry activity in this area and reassess our Do Not Track practices as necessary.
Connecting via social networks
Some of our Services may include social networking features, such as “Like” button and widgets, “Share” buttons, and interactive mini-programs. Additionally, you may choose to use your own social networking logins from, for example, LinkedIn®, to utilise some of our Services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on the Services.
Personal information pertaining to children
Our Site and Services are not intended to be used by minors and we do not want to collect information from minors. If a child’s parent or a guardian believes their child may have provided Personal Information to us, please write us using the contact details provided in “How to Contact Us” below and we will delete that Personal Information, subject to the applicable law and this Policy.
Protecting your Personal Information is important to us. We use appropriate technical and organisational measures and safeguards designed to help prevent unauthorised access, unlawful Processing, and unauthorised or accidental loss of your Personal Information. These include the implementation of appropriate policies and procedures, training for employees, contractual arrangements with vendors, third parties, customers and affiliates.