Effective May 25, 2018
This Privacy Notice is provided by J.C. Flowers & Co. LLC (“JCF”, “we” or “us”) to inform you about how we process the Personal Data that we collect through the Services. The Privacy Notice does not attempt to incorporate all relevant laws, contracts (such as partnership agreements and subscription documents, which are incorporated by reference in their entirety) and other factors which may impact personal data collection, processing and retention. This Privacy Notice does not cover or apply to our investors and limited partners. We maintain a separate Investor Privacy Notice that describes how we process the Personal Data of our investors and limited partners.
Scope and Definitions
When we use the term “Services”, we mean to refer collectively to:
When we use the term “Personal Data”, we mean information that reasonably can be used to identify an individual person or that reasonably relates to an identifiable person (a “Data Subject”).
The Data Subjects we receive Personal Data from in providing the Services are:
The Jcfco.com Site
Jcfco.com (the “Site”) is operated from servers in the United States. BY USING THE SITE AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER AND PROCESSING OF YOUR PERSONAL DATA IN THE UNITED STATES.
Please be aware that the Site may contain links to other websites hosted by third parties. JCF does not control and is not responsible for the content or privacy practices and policies of such third party websites. We encourage you to be aware when you leave the Site and to read the privacy policies of each third-party website, especially if such website collects Personal Data from you.
What Personal Data We Collect
In connection with the Services, we collect:
How We Collect Personal Data
We collect this Personal Data in various ways, including:
How We Use Personal Data
We use Personal Data for a variety of business purposes.
When processing Personal Data in connection with our Investment Services, we generally rely on our legitimate business interests. These include:
When processing Personal Data in connection with our Marketing Activities, we also generally rely on our legitimate business interests. These include:
We also may process Personal Data to perform a contract with you or to take steps at your request before entering into a contract, including to: (i) provide you with information regarding JCF Services, (ii) assist you and answer your requests, or (iii) evaluate whether we can offer you JCF Services and under what conditions.
We also may process Personal Data with your consent, but only in those cases where we make it clear to you in advance that we are relying on your consent for the processing.
How we share Personal Data
How we protect Personal Data
JCF seeks to maintain physical, electronic, and procedural safeguards in accordance with our information security program in order to protect your personal data from unauthorized access or use. However, no data transmission or storage system can be guaranteed to be secure at all times. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
How long we retain Personal Data
JCF retains personal data pursuant to our records retention program for as long as is necessary for the purposes set out in this Privacy Notice, unless a longer period is required or permitted under applicable law or is needed to resolve disputes or protect our legal rights.
Keeping Personal Data current
In general, we seek to ensure that we keep your Personal Data accurate and up to date. However, you are responsible for, and we kindly request that you inform us of, any changes to your Personal Data (such as a change in your contact details). To update or edit your Personal Data that we have on file, including your communication preferences, please contact us using the contact details set out under the “Contact and Complaints” heading below or by sending an e-mail to InvestorInformation@jcfco.com.
For individuals in the European Economic Area, please click here for additional detailed disclosures.
Contact and Complaints
JCF takes very seriously any complaints we receive about our use of your Personal Data. Questions, comments, requests or complaints regarding the Site, this Privacy Notice, the user agreement and/or our use of your Personal Data should be addressed to InvestorInformation@jcfco.com.
Any Personal Data we receive from you when making a complaint will be treated in accordance with this Privacy Notice and only to process the complaint and check on the level of service we provide. Similarly, where inquiries are submitted to us, we will only use the information supplied to us to deal with the inquiry and any subsequent issues and to check on the level of service we provide.
The below information applies to any Data Subject resident in the EEA. For purposes of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 (the “GDPR”), we act as a “data controller” and we are located in the United States at 767 Fifth Avenue, 23rd Floor, New York, NY 10153, and in the United Kingdom at 125 Old Broad Street, Floor 24, London, EC2N 1AR. As a data controller, we are responsible for deciding how we hold and use Personal Data about you.
GDPR Data Protection Principles
In respect of the collection, holding, storage, use, and processing of your Personal Data:
Transfer of Personal Data Outside of the EEA
The transfer of Personal Data from the UK/EEA to the JCF entities outside the EEA is governed by data transfer agreements, which are in the form of the standard contractual clauses approved by the European Commission (a copy of which can be obtained from us via the contact details below).
Where your Personal Data is processed by third parties outside of the EEA, we will ensure that appropriate safeguards are in place to adequately protect your Personal Data, as required by applicable law, including the execution of standard contractual clauses (referred to above) if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission) or certified under the EU-US Privacy Shield framework.
GDPR Data Subject Rights
Under the GDPR, in certain circumstances, an EEA-resident Data Subject has certain individual rights with respect to the Personal Data that we hold about them. In particular, you may have the right to:
Additionally, in the circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific purpose at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. If you decline to provide or consent to our use of the data and we are relying on consent as the legal basis for its processing, there are circumstances in which we will not be able to provide you with Services or take action on your behalf.
To exercise any of these rights, please contact us using the contact details set out under the “Contact Us” heading below. As a resident of the EEA, you are also entitled to direct any complaints in relation to our processing of your Personal Data to your national or local data protection supervisory authority. The rights described herein are not absolute and we reserve all of its rights available to us at law in this regard.
Automated Decision Making
We respect your legal rights not to be subject to decisions that are based solely on automated processing of your Personal Data, including profiling, especially where such processing has legal or other significant effects on you. In establishing and carrying out a business relationship, we generally do not use any automated decision-making pursuant to the GDPR. We may process some of your Personal Data automatically, with the goal of assessing certain personal aspects (profiling), such as to comply with legal or regulatory obligations to combat money laundering, terrorism financing, and offenses that pose a danger to assets.
|J.C. Flowers & Co
767 Fifth Avenue, 23rd Floor
New York, NY 10153
+1 (212) 404-6800
|J.C. Flowers & Co UK LLP
125 Old Broad Street, Floor 24
London, EC2N 1AR
+44 (20) 7710 0509
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Management of Cookies
Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can review your Internet browser settings, typically under the sections “Help” or “Internet Options”, to exercise choices you have for certain cookies.
Please note that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.
You can also learn more about how to manage all cookies across different types of browsers by visiting www.allaboutcookies.org. The site includes additional useful information on cookies.
We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (“DAA”). To learn more about certain third-party cookies used for interest-based advertising, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance or your device settings if you have the DAA or other mobile app.
The opt-outs described above are device- and browser-specific and may not work on all devices. If you choose to opt-out through any of these opt-out tools, this does not mean you will cease to see advertising. Rather, the ads you see will just not be based on your interests.
Please note that new services using cookies may be added to the Site from time to time. We aim to keep the cookies information as accurate as possible and use all reasonable efforts to regularly review and update the details.
 You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.