Privacy and Cookie Policy

This Privacy and Cookie Policy (this “Policy”) describes the ways in which Juniper Square, Inc., a Delaware corporation (“Juniper Square”) collects, uses, and discloses information about you, including personally identifiable information, in connection with your use of the Juniper Square portal, related applications, including Juniper Square for Outlook and the services that Juniper Square provides to you on behalf of sponsors of investment funds (“Providers”) (collectively, the “System”). Throughout this Policy, “you” refers to the individual or entity that is visiting the System. By using the System, you consent to the use of your information as set forth in this Policy.

1. This Policy.
   1. Scope. Juniper Square hosts and operates the System on behalf of Providers who, together with Juniper Square, utilize the System to provide certain investor management and communication services to you (the “Services”). In the course of providing the Services on behalf of a Provider, Juniper Square may collect “Personal Information,” which means any information relating to an identified or identifiable natural person (a “data subject”) (an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person). Juniper Square processes your Personal Information to perform the Services on behalf of Providers, or as specifically set forth in this Policy. Juniper Square is not responsible for the use of your Personal Information by a Provider; any such use will be subject to the Provider’s applicable privacy policies and terms of use.
   2. Changes to this Policy. Juniper Square reserves the right to update this Policy from time to time by posting a new Policy on this page, and in some cases where changes are material Juniper Square may also contact you via electronic mail or post a notice on the homepage to let you know of such changes. You are advised to consult this Policy regularly for any changes. Your continued use of the System after such changes have been made constitutes acceptance of those changes.
2. Collection of Information.
   1. Information that You Provide. Juniper Square collects any information that you voluntarily provide, including when you create an account on the System or when you use the Services available through the System. Information that you may provide includes your email address, name, phone number, location, and online social accounts. Juniper Square may also collect information that you provide by electronic mail, telephone or other means when you correspond with Juniper Square directly or with Providers via Juniper Square.
   2. Automatically Collected Information. Juniper Square may automatically collect certain technical information from your computer or mobile device when you use the System, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the System, the pages you view immediately before and after you access the System, and the search terms you enter on the System. This information allows Juniper Square to recognize you and personalize your experience if you return to the System using the same computer or mobile device, and to improve the System and the Services.
   3. Information about Legal and Other Materials. In addition, Juniper Square may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials and approval or execution of contracts, consents or other statements or agreements by means of the System, including the System’s Terms of Use and this Policy.
   4. Cookies. Juniper Square may collect this information using “cookies,” which are small text files that the System saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the System. Juniper Square may also collect information using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help Juniper Square compile information about your interactions with electronic mail sent to you in connection with the Services. For further information, see the Cookie Policy in Section 5 below.
   5. Information We Collect on Behalf of Providers. In providing the Services, we process Personal Information on behalf and under the instructions of Providers. We process such Personal Information as a service provider or processor (as defined by applicable law), on Providers’ behalf. In addition, Juniper Square may collect Personal Information about you from other third-party sources. For instance, a Provider that invited you to use and/or register an account on the System may facilitate the account registration process by uploading certain information about you that is already in the Provider’s possession.
   6. Cross-Site Tracking. Juniper Square does not utilize technical measures in the System to track your activities across different web sites or online services, whether you configure your browser’s Do Not Track feature or otherwise. The System does utilize third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that utilize those interfaces.
   7. Reviewing and Correcting Information. You may update or correct contact information and other Personal Information stored about you on the System by accessing your account/profile page, or by sending a written request to the Provider that provides Services to you via the System.
3. Use and Disclosure of Information. Juniper Square may collect, use, share, and otherwise process your personal information for a number of purposes, including, but not limited to:
   1. Accessing the System and Providing the Services. Juniper Square uses your Personal Information to provide you with the Services, or products, services or information related to the System or the Services; providing you with information about the System, Services or required notices; customizing your experience when using the System, such as by providing interactive or personalized elements on the System; and providing you with content based on your interests. The legal basis for such use are the System’s Terms of Use and this Policy.
   2. Analysis. Juniper Square uses your Personal Information for improving the System and/or the Services, including by (i) combining or aggregating any of the information collected through the System or elsewhere for generating and analyzing statistics about your use of the System and user demographics and traffic patterns and (ii) using anonymized data that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and for the purpose of enhancing the Services and developing new Service offerings. The legal basis for such use are the System’s Terms of Use and this Policy and Juniper Square’s legitimate interest in improving the System and Services.
   3. Marketing. If you submit your information to a Provider via Juniper Square, the Provider may provide you with information about the System, Services or required notices. In addition, the Provider may use collected information for delivering marketing communications that may be of interest to you. Juniper Square makes Personal Information about you available to the Providers who provide Services to you via the System, but does not otherwise sell or share your Personal Information with other companies so that they can market to you. You have the right to ask the Provider not to process your Personal Information for marketing purposes and Juniper Square will cooperate with the Provider in accommodating such request.
   4. Security. Juniper Square may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue Juniper Square’s legitimate interests in ensuring the security of the System and Services, including detecting, preventing and responding to fraud, intellectual property infringement, violations of the System’s Terms of Use, violations of law or other misuse of the System; and when Juniper Square believes in good faith that disclosure is necessary (A) to protect Juniper Square’s rights, the rights of Providers or other users of the System, the integrity of the System, or your safety or the safety of others, or (B) to detect, prevent or respond to fraud, intellectual property infringement, violations of the System’s Terms of Use, violations of law or other misuse of the System.
   5. Service Providers. Juniper Square engages third-party service providers (such as payment processors, hosting providers and analytics and security providers) to assist in operating and marketing the System. Juniper Square’s engagement of third-party service providers is often necessary for Juniper Square to provide the Services to you, particularly where such third-party service providers ensure that the System and Services are operating and secure. In other cases, Juniper Square has a legitimate interest in third-party service providers that can help improve the System and the Service.
   6. Other Disclosure. Juniper Square may disclose Personal Information about you to others: (a) if Juniper Square has your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of the Juniper Square terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. Juniper Square may also transfer your Personal Information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, acquisition or sale, joint venture, assignment, transfer or other disposition of all or any portion of Juniper Square’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that Juniper Square transfer Personal Information to will not be permitted to process your Personal Information other than as described in this Policy without providing you notice and, if required by applicable laws, obtaining your consent.
4. Storage.
   1. Jurisdiction. Information collected through the System will be stored in, processed in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the System, you consent to such transfer to, storage in and processing within the United States.
   2. Security. Juniper Square is committed to protecting your information from unauthorized access, use or disclosure. The system and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the System. For example, all information you transmit to the System is encrypted using Transport Layer Security technology (TLS). However, no information or communication system can be 100% secure, so Juniper Square cannot guarantee the absolute security of your information. In addition, Juniper Square is not responsible for the security of information that you transmit to the System over networks that Juniper Square does not control, including the Internet and wireless networks.
   3. Retention. Juniper Square will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. If you wish to access or correct any information Juniper Square holds about you, you may have your data deleted, blocked or corrected (as long as compliant with applicable law). Where Juniper Square processes your Personal Information on behalf of a Provider as a service provider or processor, Juniper Square will retain such information in line with the Provider’s instructions and Juniper Square’s contractual obligations. You may have the right to ask the Provider to delete, block or correct such Personal Information and Juniper Square will cooperate with the Provider in accommodating such request.
5. Cookie Policy. This section provides Juniper Square’s cookie policy and describes how Juniper Square uses Cookies and similar technologies. For more information on Juniper Square’s general data privacy practices, please see the full Policy.
   1. Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. Juniper Square uses cookies, web beacons and similar technologies (“Cookies”) to enable your user experience and to understand your usage of the System and Services. Cookies may also be set by other websites or services that provide or host content on the page you are visiting. The provision of your data via Cookies is voluntary except for those Cookies that Juniper Square places on your device because it is necessary for the performance of the System or Services. Juniper Square uses “session Cookies” and “persistent Cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the System or Services. A persistent Cookie may remain on your device for much longer until you manually delete it, or it automatically expires.
   2. Use. Cookies can contain the following information about you and your use of the System: browser type, search preferences, data relating to which pages of the System that you have visited and the date and time of your use. Juniper Square uses Cookies for the following purposes:
      1. To enable and support security features, prevent fraud, and protect your data from unauthorized access.
      2. To enable features and help us provide you with personalized content.
   3. Third-Party Cookies. Juniper Square uses the following third-party Cookies on the System:
      1. DocuSign (if applicable). Our application provides the option to execute agreements via DocuSign. If you interact with DocuSign via our application, you may encounter Cookies used by DocuSign in their internal operations. See https://www.docusign.com/company/privacy-policy for details.
      2. Wistia, YouTube, and Vimeo. Our application provides the capability to embed video from Wistia, YouTube, or Vimeo as part of a Provider’s offering marketing materials. We have configured this capability so that it uses the “privacy-enhanced” or “do not track” mode of each of these three services. In this mode, the services may set Cookies on your computer once you interact with the video player, but they will not store personally identifiable Cookie information for playbacks of embedded video. Read more about the privacy-enhanced mode for Wistia video at https://wistia.com/support/developers/player-privacy-mode, for YouTube video at https://support.google.com/youtube/answer/171780?hl=en, and for Vimeo video at https://vimeo.zendesk.com/hc/en-us/articles/360001494447-Using-Player-Parameters. See also https://wistia.com/privacy, https://policies.google.com/privacy, and https://vimeo.com/privacy for additional details about the privacy practices of these services.
      3. Zendesk. Juniper Square provides help materials via an integration with Zendesk. When you use our help center, you are interacting with a third-party website not controlled by Juniper Square and may encounter Cookies used by Zendesk in their internal operations. See https://www.zendesk.com/company/customers-partners/privacy-policy/ for details.
      4. Skilljar. Juniper Square utilizes the Skilljar platform to host our customer education material, and Skilljar uses Cookies to track the usage of that material. See https://www.skilljar.com/privacy/ for more details.
      5. Wistia. Wistia also hosts the video content embedded in both our help center and our customer education material. We have implemented this functionality so that it uses Wistia’s privacy-enhanced mode. In this mode the website may set Cookies on your computer once you click on the video player, but it will not store personally-identifiable Cookie information for playbacks of embedded videos. Read more about Wistia’s privacy-enhanced mode at https://wistia.com/support/developers/player-privacy-mode, and see https://wistia.com/privacy for additional details.
   4. Opting Out. You can control and/or delete Cookies as you wish – for details, see https://www.aboutcookies.org/. You can delete all Cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by Juniper Square.
6. GDPR.
   1. If you are a resident of the European Economic Area or the United Kingdom, Juniper Square will process your Personal Information in compliance with the EU General Data Protection Regulation (“GDPR”).
   2. Juniper Square, Inc. is a controller (as defined under GDPR), for certain Personal Information that you provide when you use the Service. For instance, your account information used to access the Service, automatically collected information about your use of the Service and cookie data. In accordance with GDPR, where Juniper Square processes your Personal Information as a controller, in certain circumstances you will have certain rights, which may include the following:
      1. right of confirmation;
      2. right of access;
      3. right to rectification;
      4. right to erasure;
      5. right of restriction of processing;
      6. right to data portability;
      7. right to object;
      8. right to withdraw data protection consent; and
      9. the right to lodge a complaint with a supervisory authority.
   3. For Personal Information that Juniper Square processes on behalf of Providers, Juniper Square is a processor, as defined under GDPR. Juniper Square is not responsible for and has no control over the privacy and data security practices of Providers, which may differ from those explained in this Policy. The data protection rights listed above do not apply to Juniper Square where Juniper Square processes Personal Information as a processor on behalf of a Provider. If Juniper Square processes your Personal Information as a processor on behalf of a Provider, and you wish to exercise any rights you may have under the GDPR or other applicable data protection laws, please inquire with the Provider directly.
7. Notice to California Residents: California Consumer Privacy Act
   
   As of January 1, 2020, verified California residents have the right to:
   • request and receive disclosure of our personal information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information;
   • request and receive a copy of the personal information we have collected about them during the prior 12 months;
   • request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose;
   • request that we not sell personal information about them; and
   • request that we delete (and direct our service providers to delete) their personal information subject to certain exceptions.
   For the purposes of this Section 7, “personal information” has the meaning given in the California Consumer Privacy Act (“CCPA”), but does not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA’s scope.
   
   In order to make a request for disclosure California residents may contact us at privacy@junipersquare.com. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time. For requests that we not sell your information, we will comply with your request within 15 days. We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
   
   You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.
   
   For requests for a copy of the personal information we have collected during the 12 months prior to your request, we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
   
   For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.
   
   We will not discriminate against you as a result of your exercise of any of these rights.
   
   Selling Information. We do not sell your information for monetary consideration and we do not disclose your information for other valuable consideration. If, in the future, we enter into arrangements that fall within the definition of a “sale” under the CCPA, we will update this privacy policy and our compliance with the CCPA.
   
   Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.
   
   During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. The business purposes for which we collect the Personal Information are described in Section 3 above. The categories include information we collect from visitors to our website that may be accessed via https://www.junipersquare.com, or from registered users, employees, vendors, suppliers and any other person that interacts with us either online or offline. Not all information is collected about all individuals. For instance, we may collect different information from applicants for employment or from vendors or from customers.
   
   

   Category of Personal Information (PI) collected	Sources of PI	Purposes of collecting PI	Categories of third parties to whom we disclose PI
   Identifiers such as full name, date of birth, nationality, gender, email address, phone number or postal address.	Information you provide us; information collected from third parties; information we may receive from third-party marketing and data partners.	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.	Service providers (such as payment processors, marketing partners, employee benefits partners; identity verification providers); government regulators; law enforcement.
   Sensitive Information such as government issued identity document such as passport, driver’s license, national identity card, state ID card, tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with legal obligations under applicable financial regulation and law.	Information you provide us; information collected from third parties.	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; internal research and development.	Service providers (such as payment processors, employee benefits partners; identity verification providers); government regulators; law enforcement.
   Commercial information such as bank account information, payment card primary account number (PAN), transaction history, and/or tax identification number.	Information you provide us; Information collected from third parties; information we may receive from third-party marketing or data partners.	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; internal research and development.	Service providers (such as payment processors, employee benefits partners); government regulators; law enforcement.
   Electronic network activity such as browsing or search history, IP address, website interactions and advertisement interactions.	Information automatically collected from visitors to our website.	Audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.	Service providers (such as payment processors, marketing partners, employee benefits partners); government regulators; law enforcement.
   Audio, video, photographs or similar information such as customer service calls.	Information you provide us; information we collect for security purposes.	Audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you; engage in marketing activities; internal research and development.	Service providers (such as payment processors and marketing partners); government regulators; law enforcement.
   Professional, educational or employment related information including office location, job title, and/or description of role.	Information you provide us; information collected from third parties; information we observe in connection with vendor or employee oversight.	To maintain legal and regulatory compliance; to review and process your employment applications; to engage in marketing activities.	Service providers (such as employee benefits partners and identity verification providers).
   Inferences drawn from the above about your preferences, characteristics, etc.	Internal analytics	To engage in marketing activities; internal research and development.	Service providers (such as marketing partners).

   As described above, we may also act as a service provider or processor to Providers who use our technology to process your Personal Information. We are not responsible for and have no control over the privacy and data security practices of such Providers, which may differ from those explained in this Policy. If your data has been submitted to us by or on behalf of a Provider and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly.
8. Third-Party Websites. The System and communications from Juniper Square may contain links to websites operated by third parties, including sites operated by Providers. You acknowledge and agree that Juniper Square is not responsible for the collection and use of your information by such websites that are not under Juniper Square’s control. Juniper Square encourages you to review the privacy policies of each website you visit.
9. Children’s Information. The System is not directed to, nor does Juniper Square knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided information without your consent, please contact Juniper Square immediately using the contact information provided below.
10. Other Agreements. You may from time to time enter into binding legal agreements relating to certain Services available through the System, which may have terms that are different from those of this Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.
11. Contact Information. If you have any questions about this Policy or the collection or use of information about you, please write to your Provider or to Juniper Square at privacy@junipersquare.com or 343 Sansome Street, Suite 600, San Francisco, CA 94104.