We are committed to protecting your personal data and we consider privacy to be fundamental to our relationship with you.
This privacy notice has been prepared to inform our limited partners, clients, investors, website users, customers and suppliers (“you”), how we collect, use and share your personal data, and the rights you have in relation to it.
This privacy notice provides general information about how we handle your personal data, however, if you have subscribed for an investment to one of our funds, please also consult your subscription documents for further information about how we handle your personal data in relation to that specific fund.
What is personal data?
Personal data means any information about a living individual from which such individual can be identified.
Examples of personal data include a person’s name, date of birth, place of residence, nationality, telephone number, tax number and individual identification documents. If a piece of data is not, of itself, able to identify an individual but can be combined with other data to identify an individual, then all of that data will be personal data.
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”, or “us”) are each a “controller” of personal data you provide to us. That means we decide the “how” and “why” of the processing of your personal data.
If you have any questions about this privacy notice or the personal data we hold about you, please contact the Firm’s compliance team using the following details:
Name: Sang Lee
Email address: firstname.lastname@example.org
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, details of which can be found online. In the UK, this is the Information Commissioner’s Office and in Guernsey this is the Office of the Data Protection Commissioner. 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.
Where appropriate, this privacy notice may be updated by us from time to time. This privacy notice was last updated on 04 October 2018.
Types of personal data we collect
We collect, handle, store, and transfer (known as “processing”) your personal data when, for example, you contact us, apply for or subscribe to an investment with us, or provide or supply a service to us (see below for more information about how we collect personal data about you).
Where you subscribe to an investment with us as a limited partner, we may also process information which you provide to us about your individual beneficial owners, representatives or other associated individuals (“associated individuals”). Where you provide personal data of associated individuals, you should make such individuals aware of the contents of this privacy notice.
The personal data about you, or your associated individuals, which we process may include:
- Personal details (such as name, address, date of birth, place of residence, domicile, address, nationality and telephone number);
- Social security number, national insurance or other tax identifier;
- Financial information (such as assets and income);
- Payment information (such as bank account details);
- Transactions with us (such as investments, withdrawals, performance and account balances);
- Instructions or requests received by us in relation to your investment;
- 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);
- Historical information (i.e., previous names and addresses); and
- Technical information (such as your internet protocol address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other similar identifying information required for your device(s) to communicate with our website).
How personal data is collected
Typically, we will collect personal data verbally, electronically or in writing from and/or about you or your associated individuals in the following ways:
- Through direct interactions when you provide personal data by filling in forms, entering into contracts or during correspondence with us. This includes when you:
- Enter into an agreement with us such as a subscription agreement, partnership agreement, management agreement, or any side letters;
- Complete documents and questionnaires related to a contract, for example “know your customer” documentation or tax forms;
- Use products and services provided by us; or
- Have meetings or calls 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;
- Placement agents, consultants or personal financial advisors;
- Third party firms which provide background checks; and
- Publicly accessible sources, such as databases.
Consequences where personal data is not provided
Certain personal data will be necessary for us to fulfill our obligations under an agreement with you, to manage your investment in one of our funds, and to comply with our statutory obligations. Failure to supply any personal data necessary for these purposes may mean that you are unable to enter into or continue your investment with us, or that we are unable to supply or receive any goods or services which you or we have requested.
How we use your personal data
Under the Data Protection Laws, we may only process personal data where we have a legal basis for doing so. The legal bases on which we may rely include where it is necessary to process personal data because:
- We have a contract with you (such as where personal data must be processed in order to perform obligations under a subscription agreement);
- We have a legal obligation (such as where personal data must be processed to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations, including confirming your identity and source of wealth); and
- We or a third party have a legitimate interest in processing the information and your interests and fundamental rights do not override those interests.
The following table sets out the ways in which we may use your personal data:
|Purpose||Lawful basis for processing|
|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||To fulfill our contract with you|
|To monitor your investment on an on-going basis||To fulfill our contract with you|
|To contact you about your investments||To fulfill our contract with you
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 in developing our products and services|
|To purchase products from our suppliers||To fulfill our contracts with suppliers|
|To use third party service providers (see below)
|To fulfill a contract with you
Necessary for our legitimate interest in managing our funds
We will only use your personal data for the purpose for which it was collected, and will only use it for another reason if we believe that new reason is compatible with the original purpose.
If we intend to use your personal data for a non-related purpose, we will tell you about that purpose and explain the legal basis under which we intend to process the personal data.
How personal data is shared with third parties
In order to provide services to you, we may provide your personal data to third parties that assist us and that have a need for such information, such as a broker, custodian, lawyer or accountant.
Generally, we will only provide personal data to third parties as permitted or required under an agreement with you and on a “need to know” basis where this is required in the normal course of our activities or is otherwise permitted or required pursuant to applicable law and/or regulation and our related policies and procedures.
We may share your personal data with the following classes of third parties:
External legal counsel or other professional advisors and their affiliates;
- Companies that assist with processing transactions, such as custodians or administrators;
- Firms that provide background checks for due diligence and anti-money laundering purposes;
- Our group companies;
- Outsourced IT consultant firms;
- Any third party to whom we assign or novate any of our rights or obligations; and
- Any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at such body or court’s request.
Certain third parties which receive personal data (for example, a custodian or administrator), may themselves be subject to regulatory requirements (such as anti-money laundering) or requests from competent bodies which require the disclosure of your personal data. Such third parties may also monitor and record calls and electronic communications for their own quality, business analysis, training, investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution. In some cases (for example, the reporting of a suspicious transaction pursuant to applicable anti-money laundering laws) these third parties may act as an independent controller of limited partner personal data.
Sending your information outside of the European Economic Area (“EEA”)
Certain third parties with which we share personal data as described in this privacy notice may include parties established in countries outside of the EEA (such as the United States) where data protection laws may not exist or where such laws may be of a lower or different standard than those in the EEA.
Where this is the case, we will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other applicable data protection law. This may include entering into the EU Standard Contractual Clauses.
Certain countries outside the EEA such as Guernsey or the United States (subject to the Privacy Shield framework) have been determined as offering an adequate level of data protection by the European Commission. In respect of transfers of your personal data from the EEA to these jurisdictions, additional safeguards may not be required.
Our compliance team can be contacted using the details above to provide further information on such safeguards if required.
We may want to contact you about products or services where we feel it will be of interest to you. We may use you or your associated individuals’ personal data to communicate with you if we have either consent for doing so or a ‘legitimate interest’.
As a commercial enterprise, we have a legitimate interest in contacting our limited partners about products or services where we believe such product or service would be of interest or beneficial for that limited partner.
You are free to free to opt-out of these communications at any time by contacting the compliance team.
Storing your information
Your personal data will be retained no longer than necessary pursuant to applicable law and regulation and our policies and procedures, in each case having regard to the purpose for which your personal data was obtained.
You are provided with a number of different rights under data protection law in relation to your personal data (depending on your jurisdiction). These allow you:
- To access your personal data;
- To request we correct your personal data;
- To request that we erase your personal data;
- To object to the processing of your personal data;
- To request a restriction in the processing of your personal data;
- To request a transfer of your personal data; and
- To withdraw your consent for certain types of processing.
If you wish to exercise any of these rights you should contact our compliance team at the details above.
You will not have to pay a fee to access your personal data or to exercise any of your other rights, however we may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive.
We may also need to seek further information from you to confirm your identity before providing any personal data or responding to a request.
We have put in place appropriate security measures to protect personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We will deal with any suspected personal data breach in accordance with data protection law and will notify you, and/or other regulators, where legally required to do so.