This Privacy Notice (the “Notice”), describes how JSK Advisory collects, uses, and shares the information that you provide to us and the information we collect in the course of operating our business and our website. JSK Advisory is contactable at contact@jsk-advisory.com.

We may revise this Notice at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you. Whenever you use our website, you are deemed to understand and agree to the terms of this Notice.

The information that we collect and where we get it from

“Personal Information” is any information that can be used to identify you or that we can link to you, and we have in our possession or control.

Information that you provide to us

We will process personal information that you give to us including when you email or contact us, or other teams, to obtain information about our firm. We store this information in our Client Relationship Management system.

How we use the information we collect

We may do the following with your personal information:

• Use it to engage in marketing and business development activity in relation to our funds and services. This may include sending you newsletters, marketing communications and other information in relation to JSK Advisory that may be of interest to you;
• To comply with our legal and regulatory obligations;
• Record and monitor your use of our website, or other online services which we provide to you, for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
• Use for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business;
• Use it to investigate any complaints or queries that you may have; and
• Use it to prevent and respond to actual or potential fraud or illegal activities

We may also collate, process, and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.

Grounds for using your personal information

We rely on the following legal grounds to process your personal information

• Consent – we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below);
• Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you;
• Legitimate interest – we may use your personal information for our legitimate interests, some examples of which are given above;
• Compliance with law or regulation – we may use your personal information as necessary to comply with applicable law & regulation.

How we share information with third parties

We may share your personal information outside of the firm, or outside of the United Kingdom or European Union. This may include

• Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers;
• Third parties relevant to the regulated services we provide. This may include, but is not limited to, counterparties to transactions or litigation, regulators, authorities, governmental institutions; and/or
• To the extent required by law, regulation, or court order, for example, if we are under a duty to disclose your personal information to comply with any legal obligation.

Where we transfer your personal information outside of the United Kingdom, or European Union, we will ensure that it is protected and transferred in a manner consistent with the legal requirements that are applicable to the information. This can be done in several different ways, for instance:

• The country to which we send the personal information may be approved by the European Commission;
• The recipient may have signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal information; or
• Where the recipient is located in the U.S., it may be a certified member of the EU-US Privacy Shield scheme.

In other circumstances, the law may permit us to transfer your personal information outside of the United Kingdom or European Union. In all cases, however, any transfer of your personal information with be compliant with applicable data protection law.

Keeping your information and information security

How long we hold your personal information for will vary and will depend principally on:

• The purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose; and
• Our legal obligations – laws or regulations may set a minimum period for which we have to keep your personal information.

We will ensure that the personal information that we hold is subject to appropriate security measures.

Your choices and rights

You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below. These rights include:

• Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you;
• Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information;
• Requesting that we correct your personal information if it is inaccurate or incomplete;
• Requesting that we correct your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are obliged under regulation to retain it;
• Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances whereby you object to, or ask us to restrict our processing of your personal information but we are entitled to refuse that request for legal or regulatory reasons;
• Withdrawing your consent. Although please note that in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so;
• Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us;
• We can, on request, tell you which data protection authority is relevant to the processing of your personal information.

If you would like further information on the collection, use, disclose or processing of your personal information or the exercise of any of the rights listed above, please contact us at contact@jsk-advisory.com.

Recruitment Privacy Notice

JSK Advisory, and its subsidiaries (“JSK Advisory”, “we” or the “Firm”) is committed to respecting your privacy and protecting your personal data. Broadly speaking, we define personal data as any and all information that directly identifies an individual or that makes an individual identifiable when combined with other information.

This Recruitment Privacy Notice (“Privacy Notice”) governs how we handle and protect your personal data in connection with JSK Advisory’s recruiting processes and programs. In case of any conflict between this Privacy Note and applicable law, applicable law will govern.

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment, and those who have directly submitted or shared their personal information with the Firm. For the avoidance of doubt, this Privacy Notice does not apply to the personal data of our employees, partners, clients, investors, vendors or any other person from whom JSK Advisory may collect personal data.

By submitting your personal data to us, you acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of your personal data as described herein.
• You are not required to provide any requested information, but your failure to do so may result in the Firm not being able to continue with your candidacy.
• This Privacy Notice does not form part of any contract of employment if offered by the Firm.

Types of Personal Data we may collect

We usually collect personal data directly from you when you apply for a role with us, such as your name, address, contact information, work and educational history, achievements, identity documents, and test results. If you receive an offer from us, we may conduct a background check and, to the extent permitted by applicable law, we may collect personal data related to criminal offences and proceedings. We may collect similar personal data about you from third parties, such as professional recruitment firms or your references. We may also collect personal information about you online, to the extent that you have chosen to make this information available publicly.

Sensitive personal data is a subset of personal data that includes ethnicity, health, philosophical beliefs, sexual orientation, and other categories as prescribed by law. We may collect sensitive personal data about a candidate to the extent permitted to do so by applicable laws. Under limited circumstances and to the extent permitted to do so by applicable law, we may collect sensitive personal information pertaining to health and medical characteristics.

Use of your personal data

We collect and use personal data for legitimate human resources and business management reasons, including:

• Identifying and evaluating candidates for potential employment, as well as for future roles should they become available;
• Maintaining records in relation to recruitment and hiring;
• Ensuring compliance with legal requirements, including those relating to public health and workplace safety;
• Fostering our diversity and inclusion programs and practices;
• Conducting background checks, including to the extent permitted by applicable law, and if you receive an offer from us, criminal history checks; and
• Protecting our legal rights to the extent authorised or permitted by law.

Legal basis for processing your personal data

Our processing of your personal data for the purposes mentioned above is based:

• In part, on our legitimate business interests in evaluating your application to manage our relationship with you, to ensure that we recruit appropriate employees, and to evaluate and maintain the efficacy of our recruitment processes.
• In part, on our performing contractual and precontractual measures relating to our potential employment relationship with you.
• In part, on our complying with applicable law with regard to personal data that is necessary to satisfy our legal and regulatory obligations.

Data Retention

If you accept an offer of employment with us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with the applicable policy. If we do not employ you, we may continue to retain and use your personal data for up to two years whereby we may consider you for potential future roles. Thereafter, we retain a minimal amount of your personal data and only in-accordance with our legal and regulatory obligation. If you request that we retain your information following a failed recruitment process, we may retain your data for a period longer than specifically mentioned above, but not exceeding five years.

To the extent that we have collected personal data, including sensitive personal data, for the sole and specific purposes of fulfilling our legal obligations, we will retain that data for the duration of those legal obligations. Thereafter, we retain a minimal amount of your personal data to establish our compliance with those obligations.

Security

We use generally accepted standards of technical and operational security to secure your personal data. Only authorised personnel of JSK Advisory and of our service providers are permitted to access personal data, and these employees are required to keep and treat information as confidential. Despite these precautions, we cannot guarantee that unauthorised persons will not obtain access to your personal data.

Your Rights

We take reasonable steps that are designed to keep your personal data accurate, complete, and up to date for the purposes for which it is collected and used. We also have implemented measures that are designed to help ensure that our processing of your personal data complies with this Privacy Notice and applicable law. You have a number of legal rights in relation to the personal information that we hold about you including:

• Obtaining information on how we process your personal information and access to the personal information which we hold about you, although there may be circumstances where we are entitled to refuse such requests;
• Requesting that we correct your personal information if it is inaccurate or incomplete;
• Requesting that we erase your personal data;
• Objecting to, and requesting that we restrict our processing of your personal information in certain circumstances, although there may be circumstances where we are entitled to refuse that request for legal or regulatory reasons;
• Withdrawing your consent. Although please note that in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so;
• Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us;
• We can, on request, tell you which data protection authority is relevant to the processing of your personal information.