Data protection privacy notice 

We are committed to protecting your personal information and ensuring we respect your privacy.  This Privacy Notice explains how we will look after and use any personal information that we collect about you. 

What is personal information? 

Personal information means any information about you from which you can be identified.  Examples of personal information include your name, home address, personal identification numbers, date of birth, telephone number and e-mail address, but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie. 

Who we are 

Jordan/Zalaznick Advisers, Inc. (“JZAI”), JZ Asset Management LLC (“JZAM”), JZ International Ltd ("JZI"), Jorza International España, S.L. ("JIE") and JZ Asset Management UK LLP (“JZAM UK”) (together the “Group”, the “Firm”, “we”, “us”) are controllers of personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you, please contact the Firm’s compliance team using the details set out below: 

Full name of legal entity:  Jordan/Zalaznick Advisers, Inc.

Name of relevant contact:  Sang Lee

Email address:  slee@jzadvisersinc.com

Postal address:  Jordan/Zalaznick Advisers Inc., 9 West 57th Street, 33rd Floor, New York, NY 10019, USA

Contact telephone number:  +1 (212) 485 9706 

You have the right to make a complaint at any time to the data protection authority in your jurisdiction. In the UK, this is the Information Commissioner’s Office (“ICO”).  We would, however, appreciate the chance to deal with your concerns before you approach any data protection authority, so please contact us in the first instance.

What types of information do we use? 

We collect, store, and transfer (“Process”) information in the course of providing our financial services to you.  The information about you which we Process may include: 

  • Employment details (job title, company name, address, etc.);
  • Payment information (i.e., bank account);
  • Employment or work history/background;
  • Contractual/contact information (i.e. our ‘history’ together – services provided or discussed);
  • Instructions or requests;
  • Financial information (financial position and history);
  • Documentary data (i.e., passport, driver’s license or other forms of identification);
  • Public records (or openly accessible data) such as the Electoral Register;
  • Social and or demographic (profession, work, nationality, income); and
  • Historical information (i.e., previous names and addresses). 

Consequences of not providing some types of information 

Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the goods or services you asked for.  In this case we may have to cancel the product or services, but we will tell you if this is the case. 

How do we collect information about you? 

Typically, we will collect information from you when you contact us directly or provide information in order for us to provide our products and services.  We collect information from and about you in the following ways: 

Through direct interactions when you give us your personal information by filling in forms or during correspondence with us.  This includes when you: 

  • Meet with us in person or talk to us face to face;
  • Receive marketing materials from us;
  • Complete questionnaires, for example, to give us feedback or provide additional information; or
  • Enter into a contract with us. 

Through using our website when we collect information using cookies or similar technologies which tell us about your equipment, browsing actions and patterns. 

Through third parties such as fraud prevention agencies.  We may also receive personal information from other companies and organizations such as placement agents, consultants or personal financial advisers. The third parties which we receive personal information from are as follows: 

  • Third party data sources;
  • Third party firms which provide background checks; and
  • Publicly accessible sources, such as databases. 

How we will use your personal information 

We only obtain, use and keep personal information where we need it for a specific purpose.  We set out in the table below the ways in which we plan to use your personal information.  We are only able to use your personal information if we have a proper legal reason or basis for doing so.  Regulations require that we have a legal basis so that your privacy is protected.  The legal bases on which we rely include: 

  • We have a contract with you. For example, we have agreed to provide financial advice or to manage investments for you and have a contractual agreement to do this.
  • We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations.  For example, this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
  • We, or a third party, have a legitimate interest in processing the information and your interests and fundamental rights do not override those interests. For example, processing your information to prevent fraud. 

We set out in the table below all the ways we plan to use your personal information and the legal bases we rely on to do so.  We also explain what our legitimate interests are where appropriate: 

Purpose

 

Lawful basis for processing including our legitimate interests

To on-board you as a new client

To fulfill our contract with you

To fulfill our legal obligations to prevent financial crime and the financing of terrorism

To manage your account

Necessary for our legitimate interests

To monitor your investment on an on-going basis

To fulfill our contract with you

To contact you about your investments

To fulfill our regulatory obligations

To contact you about other products and services  we think you may be interested in based on products or services you have previously acquired from us or in which you have expressed an interest

Necessary for our legitimate interests – to develop our products and services and grow our business

To purchase services from our suppliers

To fulfill our contracts with suppliers

We will only use your personal information for the reason which we collected it.  We will only use it for another reason if we believe that new reason is compatible with the original purpose.  If we do need to use your personal information for a non-related purpose, we will tell you about it and explain the legal basis which allows us to do so. 

Marketing

We want to contact you about products or services we feel will be of interest to you or of benefit. We use your personal information to communicate with you if we have either your consent or a ‘legitimate interest’. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our products or services and we will only do so if we decide it would be of interest or beneficial for you. However, if we are contacting you as a private individual we will also gain your consent to do so. If so, we will always ensure we seek consent from you in a way which is clear and explains why we are seeking consent to use your personal information. We will very clearly explain why we are seeking your consent and ensure that you are provided with a simple method of providing this. 

You are free to change your mind at any time by contacting the compliance team. 

Name:  Sang Lee

Position:  Chief Compliance Officer & Chief Financial Officer

Phone:  +1 (212) 485 9706

Email:  slee@jzadvisersinc.com

Address:  Jordan/Zalaznick Advisers Inc., 9 West 57th Street, 33rd Floor, New York, NY 10019, USA 

Who we share your information with 

We may need to provide information to third parties for a variety of reasons; for example, we may need to provide information to assist in the management of your investments with us or the detection or prevention of crime.  Please refer to the table in the section ‘How we will use your personal information’ which explains how we use your data.  The third parties we share your information with are as follows: 

  • Other Group companies
  • External legal counsel
  • Auditors
  • Our outsourced IT consultant firms
  • Companies that assist us with processing your transactions such as custodians or administrators
  • Firms that provide us with background checks for due diligence and anti-money laundering 

Sending your information outside of the European Economic Area (“EEA”) 

The regulations which have been put in place to protect your privacy apply throughout the EEA.   As explained in the section above, we may send your information to our group companies who are based outside of the EEA, however we will only share your information with them because the following safeguards have been put in place: 

  • The information is being transferred between organizations (in this case, organizations within the Group) which are engaged in the same economic enterprise, or within our corporate group;
  • The entities we transfer your information to have entered into standard contractual clauses for the transfer of personal data to third countries as approved by the European Commission (copies of this agreement are available on request to the contact details above). 

You can obtain further information on the specific mechanism used by us when transferring your personal information outside of the EEA by contacting the compliance team. 

Storing your information 

The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorized use or disclosure. We will ensure all records are safely destroyed if you have contacted us to request so. 

Your rights 

You are provided with a number of different rights under the data protection laws in relation to your personal information.  These allow you: 

  • To access your information;
  • To request we correct your information;
  • To request that we erase your information;
  • To object to the processing of your information;
  • To request a restriction in the processing of your information;
  • To request a transfer of your information; and
  • To withdraw your consent.

If you wish to exercise any of these rights please contact our compliance team, referenced above. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights.  We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request.  We may also need to seek further information from you to confirm your identity before we release any personal information.  This does not affect your right to make a complaint to the ICO. 

Security 

We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.  We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.