Privacy Policy

JORDAN PARK GROUP PRIVACY NOTICE

Last Updated April 23, 2025

This privacy notice (“Privacy Notice” or “Notice”) describes how Jordan Park Group LLC (“Jordan Park,” “we,” “us,” “our”) collects and processes Personal Information (defined below) we collect in the course of conducting business, visiting our website, or when individuals apply for a job with us through our website, and describes rights residents of certain states may have with respect to their Personal Information. It does not apply to information we collect about individuals when acting in their capacity as employees or independent contractors. Depending on who you are and the nature of your interaction with Jordan Park, some of the Personal Information we collect may be nonpublic personal information. For purposes of this Notice, “affiliated entities” are companies related by common ownership or control, which may include financial and nonfinancial companies.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular client or household.

Notice at Collection: Personal Information We Collect

Jordan Park collects the following categories of Personal Information, which may include nonpublic information:

Personal identifiers: Name, address, email address, telephone numbers, social security number, tax identification number, birth date, IP address or other unique identifier, account name and password, identification documents for anti-money laundering (“AML”) that may be received in account documents and related forms and other similar information, eligibility to work in the U.S. and visa status information.
Financial information: Bank account information, account activity, assets, income, investment experience and activity, financial goals, and account balances.
Protected class information: Age, gender, gender identity or expression, race or ethnicity, veteran status, disability status (some of which is voluntarily provided during the job application process).
Commercial information: Records of products or services purchased or considered, consuming histories or tendencies.
Internet or other electronic activity information: Device and browser type, your browsing and search history on our website, and information regarding your interaction with our website.
Educational information: Schools attended; graduation history; certificates received.
Professional information: Current and former Job titles, employers, dates of employment, job history information, security industry registrations, Form U4 disclosures and information about disciplinary actions, LinkedIn profile link, and Jordan Park application history information.
Inferences drawn from Personal Information collected.
Sensitive Personal Information: social security number, tax identification number, eligibility to work in the U.S. and visa status information, disability status.

We collected the same categories of Personal Information in the 12 months prior to the date of this Notice.

Notice at Collection – Purposes for Collection of Personal Information

We use the Personal Information we collect to provide financial products and services to our customers, to manage and administer your holdings, including assessing and processing applications and redemptions, servicing accounts, processing transactions, maintaining investor accounts and communicating with you about your holdings and account related activities on an ongoing basis, to market to existing and prospective customers, for information security and fraud detection, and to maintain our relationships and fulfill our obligations to our customers. We also may use your Personal Information to process your job application and evaluate you as a potential hire. We may also use your Personal Information to enforce or defend our rights, or those of another client or other third party. Jordan Park will collect and use Personal Information in the course of business for tasks such as, the execution of account documents, for the legitimate interests of Jordan Park and to enable Jordan Park in complying with its legal and regulatory obligations.

Your Federal Privacy Rights – Marketing Communications Opt-Out

Jordan Park may use certain Personal Information about you for the purpose of sharing information about products and services we believe may be of interest to you. You have the right to choose not to receive communications regarding Jordan Park’s products and services offerings from Jordan Park and our affiliates. If you wish to opt-out of receiving these marketing or market research communications, you can contact Jordan Park to opt-out at (415) 417-3000 or privacy@jordanpark.com.

Jordan Park does not sell Personal Information or share it for the purposes of cross-context behavioral advertising.

Notice at Collection – Retention

Jordan Park will retain Personal Information for a minimum period of six years or for as long as required for us to perform the services, and as required by law. Regarding data we collect related to website usage, we will retain Personal Information only for as long as is relevant for the purposes for which it was collected. Jordan Park complies with applicable legal or regulatory obligations regarding data retention and for any other legitimate business reasons, and we may retain Personal Information for longer or shorter durations, as appropriate. We expect to delete Personal Information (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining that Personal Information.

Sources From Which We Collect Personal Information

We collect Personal Information from our clients’ business contacts, and job applicants, as well as from other financial institutions or referral sources. We may also automatically collect information through the use of cookies and other tracking technologies.

Use or Disclosure of Sensitive Personal Information

We do not use or disclose Sensitive Personal Information to infer characteristics about individuals or for any purposes other than to operate our business.

Disclosures of Personal Information for Business Purposes

Financial companies like Jordan Park choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. The following chart describes the categories of Personal Information we have disclosed to third parties for a business purpose in the 12 months prior to the date of this Privacy Notice:

Categories of Consumers’ Personal Information	Categories of Third Parties to Whom We Disclosed Personal Information for a Business Purpose
Personal identifiers: Name, address, email address, telephone numbers, social security number, tax identification number, birth date, IP address or other unique identifier, account name and password, identification documents for anti-money laundering (“AML”) that may be received in account documents and related forms and other similar information, eligibility to work in the U.S. and visa status information*.	Service providers that provide customer relationship management; facilitate account management; process transactions and investments; maintain client records and provide centralized administrative and marketing services for clients; investigate and resolve complaints and manage litigation; monitor IT systems for data security incidents, fraud, or crime detection or for regulatory reasons; comply with applicable AML policies; assist in processing job applications and meeting related regulatory requirements; assist us in operating, analyzing, and displaying content on our website; provide analytics information; marketing services; provide advertising and marketing services; provide website hosting, webcast and teleconference services; provide legal and accounting services.
Financial information: Bank account information, insurance information, account activity, investment activity and financial goals, and account balances.	Service providers that provide customer relationship management; facilitate account management; process transactions and investments; maintain client records and provide centralized administrative and marketing services for clients; investigate and resolve complaints and manage litigation; monitor IT systems for data security incidents, fraud, or crime detection or for regulatory reasons; comply with applicable AML policies; provide legal and accounting services.
Protected class information: Age, gender, gender identity or expression, race or ethnicity, veteran status, disability status*.	Service providers that provide customer relationship management; assist in processing job applications and meeting related regulatory requirements; provide legal services.
Commercial information: Records of products or services purchased or considered, consuming histories or tendencies.	Service providers that provide customer relationship management; provide advertising and marketing services.
Internet or other electronic network activity information: Device and browser type, browsing and search history on our Sites, and information regarding interaction with our Sites and our advertisements.	Service providers that provide data security services and cloud-based data storage; provide customer relationship management; host our Sites and assist with other IT-related functions; provide website hosting, webcast and teleconference services; advertise and market our products; and provide analytics information.
Educational information: Schools attended; graduation history; certificates received.	Service providers that assist in processing job applications and meeting related regulatory requirements.
Professional information: Current and former Job titles, employers, dates of employment, job history information, security industry registrations, Form U4 disclosures and information about disciplinary actions, and Jordan Park application history information.	Service providers that assist in processing job applications, assist with background checks and operational due diligence, and meeting related regulatory requirements.
Inferences drawn from Personal Information collected.	Service providers that provide advertising and marketing services; provide analytics services provide customer relationship management; provide investment opportunity management.

* – Denotes Sensitive Personal Information

Business Purposes for the Disclosure of Personal Information

Jordan Park may disclose each of the categories of the Personal Information we collect to third party service providers, governmental authorities, or to other third parties including other financial institutions as directed by the customer or otherwise required or permitted by law for the following purposes: entering into account documents; processing transactions and investments; maintaining client records and providing centralized administrative and marketing services for current and prospective clients; investigating and resolving complaints and recording calls and managing litigation; monitoring electronic communications and other IT systems for data security incidents, fraud, or crime detection or for regulatory reasons; evaluating job applicants; and to satisfy our legal obligations.

Additional Information About How We May Disclose Personal Information

All financial companies need to share customers’ Personal Information to run their everyday business. We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property, or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your Personal Information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

Cookies and Other Tracking Technologies

Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

When you visit our website, we may place a “cookie” or other online tracking devices (e.g., web beacons) that recognizes you. The cookies and other tracking technologies may also collect information about your IP address or actions taken in connection with our website. We may use cookies or similar tracking technologies to capture information about the use of our websites, including to improve your user experience. Accordingly, we may store and retrieve information on your device through the use of cookies and similar technologies. Some of these technologies are from third parties. For example, we use Google Analytics to collect information and help us understand how visitors engage with our website. Click this link (https://marketingplatform.google.com/about/analytics/terms/us/) to learn more about how Google collects and processes information in connection with the services it provides to us.

U.S. State Data Privacy Rights

State privacy laws in various states give state residents various rights with respect to many types of Personal Information we collect about them, with some exceptions. In addition, there will be state privacy laws in other states that come into effect after the date of this Privacy Policy. The rights provided under these laws are similar in many respects, with some differences from state to state. We list below the rights that may be applicable to our business under these laws, noting that not all rights are available under each state’s law:

Your Right to Know, Access and Request Disclosure of Information We Collect and Share About You

Jordan Park is committed to ensuring that you know what information Jordan Park collects and shares about you. You have the right to confirm whether or not we are processing your Personal Information and to access such data, including receiving a copy of such data, subject to certain exceptions.

Laws in some states provide the right to know more detailed information. Depending on your state of residence, you may have the right to submit a request to Jordan Park for the following information:

The categories of Personal Information that Jordan Park has collected about you.
The categories of sources where Jordan Park collected the Personal Information.
The business or commercial purposes for why Jordan Park collected the Personal Information.
The specific pieces of Personal Information we collected about you.
The categories of third parties with whom Jordan Park shared your Personal Information.
The categories of Personal Information that we’ve shared with service providers who provide services for us.

Certain state privacy laws also give residents the right to request a list of third-party entities to which we have disclosed Personal Information.

Your Right to Request Deletion of Personal Information We Have Collected About You

Upon your request, we will delete the Personal Information we have collected about you, except for situations where the law authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.

To exercise your rights to know, access, delete, or correct your Personal Information, contact Jordan Park at privacy@jordanpark.com or (415) 417-3000. Requests are typically free of charge. If your request relates to Personal Information we may have collected from or about you when you applied for a position with us, please submit your request by contacting us at PeopleTeam@jordanpark.com or (415) 417-3000.

Your Right to Request to Correct Personal Information We Hold About You

You have the right to request that we correct Personal Information we hold that you believe is not accurate. We will take steps to determine the accuracy of the Personal Information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the Personal Information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct in order to assist us in evaluating the request.

Your Rights to Opt Out

Depending on your state of residence, you may also have certain qualified rights to request that we stop using your Personal Information for one or more of the following purposes.

Sale of Personal Information: The right to request that we stop selling your Personal Information, consistent with the definition of “sale” in each law. We do not engage in sale of Personal Information.
Targeted Advertising: The right to request that we stop processing your Personal Information for targeted advertising, subject to exceptions in some state laws. We do not process your Personal Information for targeted advertising.
Sharing for Cross-Context Behavioral Advertising: California’s law provides the right to request that we stop sharing Personal Information for cross-context behavioral advertising. We do not share Personal Information for cross-context behavioral advertising.
Profiling In Furtherance of Legal or Significant Decisions: The right to request that we stop processing Personal Information for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects. This includes the provision or denial of financial or lending services, insurance, employment, etc. We do not profile in furtherance of legal or significant decisions as described here.

Our Commitment to Honoring Your Rights

If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly.

Our Process for Responding to Requests

We will respond to requests from residents of states with data privacy laws that apply to us and will do so with respect to the rights that are provided under the requestor’s state law as of the effective date of that law.

To respond to your request, we will ask you for certain pieces of Personal Information and endeavor to match those to information we maintain about you. The nature and number of verifying data elements we may request will depend on the nature of your request and the nature of the information we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. In that case, we will notify you to explain the basis of our denial.

For requests for access, deletion, or correction, we will respond to your request or your authorized agent’s request in writing as soon as practicable and in any event generally not more than within 45 days after receipt of the request. If we require additional information or need to extend the period to process your requests, we will explain to you or your authorized agent why we did so.

Do Not Track

We do not respond to “Do Not Track” signals.

Authorized Agents

If you are legally entitled to such rights under state data privacy laws, you may designate an agent to submit a request on your behalf; this is not an option that is available under all state data privacy laws, though. If you would like to designate an agent to act on your behalf, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.

Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with state law pertaining to powers of attorney.

When We Do Not Act on a Request – Appeal Process

In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.

Additionally, you have the right to appeal our decision by contacting us at privacy@jordanpark.com or (415) 417-3000 within 30 days after your receipt of our decision.

Non-Discrimination

If you exercise any of the rights explained in this Notice, we will continue to treat you fairly. If you exercise your rights under this Notice, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.

International Transfers

If you are located in a jurisdiction outside the United States, Jordan Park may disclose Personal Information collected from you to recipients located in countries outside of the jurisdiction in which you live, including Jordan Park’s service providers in the United States as well as outside of the United States. Such countries may not have data privacy laws equivalent to your home country.

By submitting your Personal Information to Jordan Park and the other recipients described in this Privacy Notice that are located in countries outside of your home country, each client consents to the transfer of their Personal Information to Jordan Park and the other recipients described in this Privacy Notice. Clients may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Information Security

Jordan Park is committed to maintaining your trust and confidence. We employ reasonable information security policies and procedures based on recognized industry standards to protect your information, such as the use of physical, technical, and procedural controls in keeping with federal standards to safeguard Personal Information. However, no security system is impenetrable. In addition, no transmission or electronic storage of information is guaranteed to be secure.

Use caution when transmitting information via the Internet, select strong and unique passwords that are not reused at any otherwise, protect the confidentiality and security of their online passwords, and to immediately alert us to any concerns with your account or passwords. Please always use caution when transmitting information over the Internet, use strong and unique passwords that you do not also use on other online services, and notify us immediately of any concerns with your account or passwords.

Children’s Privacy

Jordan Park’s services are not intended for and are not directed to minors under the age of 13. We do not knowingly collect or sell any Personal Information about children under 16 years of age without parental consent.

Third Party Websites and Social Media Buttons

Our website may contain links to other third-party websites and social media buttons that connect to third party websites or applications with their own privacy policies. We are not responsible for the activities and practices that take place on these websites or applications. Accordingly, we recommend that you review the privacy policies posted on any website that you may access through our website.

Other Privacy Notices You May Receive From Us

This Privacy Notice supplements the information set out in the subscription documents made available to you. However, for the avoidance of doubt, it is not intended to modify or override any representations made or commitments given by you (whether on your behalf or on behalf of others) in those documents.

Accessibility

Jordan Park is committed to ensuring that our communications are accessible to individuals with disabilities. Individuals with disabilities can access this Notice in alternative formats by contacting us at the address, phone, or email address below. This Privacy Notice is designed to meet content accessibility guidelines. To submit accessibility-related requests or report barriers to accessibility, please contact us at (415) 417-3000 or contact us at privacy@jordanpark.com.

Changes to this Notice

We may review and update this Notice from time to time. If changes are made, we will update the Privacy Notice and reflect the date of such modification in the date above. If the changes are material, you will be notified via a notice on our website.

Contact Us

If you have any further questions about our Privacy Notice or practices, please contact us at:

Jordan Park Group LLC
100 Pine Street
San Francisco, CA 94111
privacy@jordanpark.com
(415) 417-3000