Last Updated June 15, 2023
This privacy policy for California residents (this “California Privacy Policy”) is provided in addition to any other privacy policy provided by Jadian IOS (collectively, “Jadian,” “we,” “our,” or “us”), including the Jadian IOS Privacy Policy, and explains Jadian’s online and offline collection, use, and disclosure of Personal Information relating to residents of the State of California (“consumers,” “you” or “your”) covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and provides information regarding how such California residents can exercise their rights under the CCPA.
This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. If you are an investor, our policies and practices regarding the collection and processing of your Personal Information are detailed in our Jadian Capital Investor Privacy Notice. This California Privacy Policy is available in alternative formats upon request. Please contact privacy@jadiancapital.com or (212) 503-5900 to request this California Privacy Policy in an alternative format.
Our Collection, use, retention and disclosure of Personal Information.
Sales and Sharing of Personal Information. We do not and have not sold any categories of Personal Information to third parties or shared any categories of Personal Information for the purpose of cross-context behavioral advertising purposes.
Collection, Sources and Use of Personal Information. We have collected and used the following categories of Personal Information from the following sources and for the following business purposes during the 12-month period prior to the “lasted updated’ date of this California Privacy Policy:
| Categories of Personal Information | Sources | Business Purposes |
|---|---|---|
| “Identifiers,” including name, contact details (including address, telephone number, email address and Internet Protocol address), cookies, beacons, pixel tags, mobile ad identifiers and similar technology), and other online identifiers. | • “Directly from you,” including, for example, through your use of the website, when you send us an email, visit our premises, or otherwise contact or communicate with us; • “From automated tracking technology and monitoring tools,” such as cookies, that track your access and use of our website and other online services; • “From within Jadian and from our affiliates”; • “From counterparties and intermediaries”; • “From businesses that we are evaluating” in connection with a potential investment or business opportunity”; • “From vendors,” including service providers, advisors and other business partners; and • “From recruiting sources,” such as agencies, social media networks and publicly available sources. |
• “Providing services”; • “Auditing and verifications,” including but not limited to verifying the quality and effectiveness of services and compliance; • “Short-term, transient uses”; • “Protecting our systems,” including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible; debugging to identify and repair errors that impair intended functionality; • “To comply with legal obligations,” such as in connection with a valid court order, judicial subpoena or regulatory inquiry, and as required by law enforcement agencies, federal or state regulatory agencies, or self-regulatory organizations; and • “In connection with a corporate transaction,” such as a sale, merger or other change in corporate control or a restructuring or bankruptcy. |
| “Other records,” including signature, physical characteristics or description; bank account number, other financial information (including accounts and transactions with other institutions); driver’s license or other state ID card number, or passport number; medical information and health insurance information; and verification documentation (including social security number, tax status, income and assets). | Directly from you; from automated tracking technology and monitoring tools; from within Jadian and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction. |
| “Protected classifications” under California or federal law, including race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status. | Directly from you; from automated tracking technology and monitoring tools; from within Jadian and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction. |
| “Commercial information,” including your investment information, including financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies. | Directly from you; from automated tracking technology and monitoring tools; from within Jadian and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction. |
| “Online activity,” including your Internet and other electronic network activity information (e.g., browsing history, search history, and information regarding your interaction with websites, applications or advertisements). | Directly from you; from automated tracking technology and monitoring tools; from within Jadian and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction. |
| “Employment Information,” including your professional or employment-related information. | Directly from you; from automated tracking technology and monitoring tools; from within Jadian and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction. |
| “Other information” you create or provide to us, including the content of your communications with us. | Directly from you; from automated tracking technology and monitoring tools; from within Jadian and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with a corporate transaction. |
We do not knowingly collect or solicit any categories of Personal Information from any individual under the age of eighteen (18).
Sensitive Personal Information. Sensitive Personal Information may include social security numbers, driver’s license numbers, or passport numbers; account credentials; precise geolocation; racial or ethnic origin; religious beliefs; biometric data; personal information concerning a consumer’s health or sex life or sexual orientation; as well as contents of a consumer’s mail, email and text messages. To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect and investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient use; (vi) to perform services necessary for the business; (vii) to verify and maintain the quality and safety of our product or services; and (viii) generally for purposes that do not infer characteristics about you.
Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected. For additional information on how we store your Personal Information, please refer to Section 5 (Retention) of the Jadian IOS Privacy Policy.
Disclosures of Personal Information for Business Purposes. We have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes during the 12-month period prior to the “last updated’ date of this California Privacy Policy:
| Business Purposes | Categories of Recipients | Categories of Personal Information |
|---|---|---|
| Performing and providing the services that we offer. | Service providers, contractors, advisors and others who provide services to us or on our behalf (together, “service providers and contractors”); professional services organizations, such as auditors, tax advisors and law firms (together, “professional advisors”); prospective lenders to or creditors of an entity in which we have or are considering investing. | Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information. |
| Auditing and verifications, including but not limited to, verifying the quality and effectiveness of services and compliance. | Service providers and contractors; professional advisors; prospective lenders to or creditors of an entity in which we have or are considering investing. | Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information. |
| Short-term, transient uses. | Service providers and contractors. | Identifiers; Other records; Protected classifications; Commercial information; and Online activity. |
| Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. | Service providers and contractors. | Identifiers; Other records; Online activity; Employment information; and Other information. |
| To comply with legal obligations such as in connection with a valid court order, judicial subpoena or regulatory inquiry, and as required by law enforcement agencies, federal or state regulatory agencies, or self-regulatory organizations. | Government entities; counterparties and intermediaries; and professional advisors. | Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information. |
Your California Privacy Rights.
Your CCPA Privacy Rights. You have certain choices regarding our use and disclosure of your Personal Information, as described below.
Know: You have the right to request, twice in a 12-month period, that we provide (A) certain information about (w) the categories of Personal Information we have collected about you; (x) the categories of sources from which the Personal Information is collected; (y) the business or commercial purpose for collecting your Personal Information; and (z) the categories of third parties with whom we have shared your Personal Information; and/or (B) the specific pieces of Personal Information we have collected, used, and disclosed about you during the past 12 months.
Deletion: You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
Correction: You have the right to request that we correct or amend certain Personal Information we maintain about you if it is inaccurate.
Limit: You have the right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. If Jadian collects any sensitive personal information, it will use it only for purposes listed above in Section 1(c). As such, any sensitive personal information that we collect does not come within this right to limit use.
Opt-out: You have the right to opt out of the sale of your Personal Information to third parties and/or the sharing of your Personal Information for certain purposes.
Non-Discrimination: You have the right to not experience discriminatory treatment and we will not discriminate against you because you have exercised any California consumer privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
How to Submit a Request. You may submit a request by using one of the following methods.
Call: (212) 503-5900
Email us: privacy@jadiancapital.com
Verifying Your Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
Consumer Verification. If you request to know, access, delete, and/or correct your Personal Information, we may require you to provide any of the following information: address, date of birth, state or country of residence, telephone number, email address, or details of a transaction. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.
Client Verification. If you are a current client, we may ask that you log into Jadian’s online portal for investors (located at https://citcoone.citco.com/) and make the request through your online account, or require certain verifying information such as your account number, last four digits of your Social Security Number or tax-identification number, and/or government issued identification. In addition, a callback may be required to verify the authenticity of the communication.
Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (A) provide the authorized agent written permission (e.g., via a notarized letter) to do so, and (B) verify your own identity directly with us (as described above), and confirm with us that you provided the authorized agent permission to submit the request.
Additional California Privacy Disclosures.
Do Not Track Signals. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
Shine the Light Notice. California residents may request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in Section 2(b), above.