Privacy Policy

Introduction

Jordan & Jordan (also referred to below as "J&J") is a privacy conscious organization. This Privacy Policy explains how J&J protects your information gathered (1) via our clients in the course of processing data in conjunction with our market data reporting, compliance and audit practices; or (2) collected as part of personnel records for the purposes of human resources in conjunction with employment at J&J. 

Information collection

We may collect personal information in conjunction with our market data reporting, compliance and audit practices. Such information may consist of name, current job title, home address, company address, email address, telephone and fax numbers, correspondence with you, and other information you provided to us through our clients.
We may also collect personal information in conjunction with your employment at J&J for human resources purposes.
We do not usually seek to collect sensitive personal information (i.e., data relating to race or ethnic origin, religious or philosophical beliefs, trade union membership, political opinions, medical or health conditions, or information specifying the sex life or sexual orientation of an individual) from users. We will, where necessary, obtain your explicit consent to collect and use such information.

Privacy Shield Notice; Information transfers

J&J complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. J&J has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.  Unless indicated otherwise with respect to a particular transfer, J&J relies on the Privacy Shield for such transfer.

Our Privacy Shield certifications cover personal information regarding:

(1) current, former, and prospective partners, principals, and employees (collectively "Personnel") in connection with the Personnel relationship; and
(2) personal information regarding clients and their personnel and customers in connection with the client relationship, such as the delivery of market data reporting or compliance services and the administration of the client relationship.

We do not disclose personal information to third party service providers in connection with the operation of our business, including our provision of services to clients and our Personnel and business relationships.  Although J&J does not currently transfer data to third parties, J&J remains liable under the Privacy Shield principles in the event that we begin to transfer data to third parties in the future.  In the context of an onward transfer, J&J would have responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf.  J&J would remain liable under the Privacy Shield if its agent processes such personal information in a manner inconsistent with the Privacy Shield principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

J&J is subject to the investigatory and enforcement powers of the United States Federal Trade Commission. J&J may be required to disclose personal information to law enforcement, regulatory or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.
In compliance with the Privacy Shield Principles, J&J commits to resolve complaints about our collection or use of your personal information.  Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact J&J at privacy@jandj.com.   J&J commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.

J&J has further committed to refer unresolved Privacy Shield complaints regarding non-HR data to the International Centre for Dispute Resolution/American Arbitration Association ("ICDR/AAA"), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit the ICDR/AAA website here for more information or to file a complaint.  The services of the ICDR/AAA are provided at no cost to you.

J&J could be obligated, under certain conditions, to arbitrate claims and follow the terms as set forth in Privacy Shield Annex I, provided that an individual has invoked binding arbitration by delivering notice to J&J and following the procedures and subject to conditions set forth in Privacy Shield Annex I.

Information use

We collect and use personal information provided to us by our clients in conjunction with the performance of our market data reporting, compliance and audit services, or where we have a legitimate business interest in or other legal basis for, such collection and use. With regard to market data reporting, the personal information may be utilized to associate market data usage to a unique user and confirm the users are natural persons. In respect of compliance, we may receive certain personal information in conjunction with the performance of our surveillance service or during regulatory assessments.  For auditing purposes, we may utilize data to confirm employment, validate natural persons users of market data or determine professional/non-professional status. 

Disclosure of information to third parties

Personal information may also be disclosed to law enforcement, regulatory, or other government agencies, or to other third parties, in each case to comply with legal, regulatory, or national security obligations or requests.
All of these disclosures may involve the transfer of personal information to countries or regions without data protection rules similar to those in effect in your area of residence.

Information retention

We retain personal information as necessary for the duration of the purpose outlined in this Privacy Policy. Notwithstanding the duration of the purpose, we may retain your information if necessary to comply with our legal or professional obligations, enforce our agreements, or resolve disputes.

Rights to access and control your personal information

You have choices about how your personal information is collected, used, and shared.
Under applicable law, you may have the right to access or obtain a copy of the personal information that we have collected about you, or to review, modify, delete, or to request that we stop processing such personal information. If you have any questions, please contact us at privacy@jandj.com.

Applicable laws may give you the right to lodge a complaint with a local supervisory authority related to this Privacy Policy.

Special notices to California residents

In response to California law, if you are a California resident, you are entitled to request information concerning whether your personal information has been disclosed to nonaffiliated third parties for their direct marketing purposes. We do not share your personal information with nonaffiliated third parties for such purposes.

Information security

We have in place reasonable commercial standards of technology and operational security to protect all personal information provided by clients from unauthorized access, disclosure, alteration or destruction.

Changes to our Privacy Statement

We may modify or amend this Privacy Policy from time to time at our discretion. When we make changes to this Privacy Policy, we will amend the revision date at the top of this page and such modified or amended Privacy Policy shall be effective as to you and your information as of that revision date. We encourage you to periodically review this Privacy Policy to view any updates.

Contact information

If you have any questions or concerns regarding your privacy, please contact us at privacy@jandj.org.