Updated October 26 2018
Jupiter Island Capital, its subsidiaries and affiliates (collectively, “Jupiter Island Capital”, or “we”, “us”, “our”) respect the privacy and security of your personal data.
Our purpose in collecting information is to help us provide you with better service, for example through notifications about special offers and promotions or other relevant content delivered through targeted advertising.
You may choose to use our services or to receive additional information from us, for example by submitting a registration form containing certain information in order to access free content. When you request our services or register to receive information, we collect the following Personal Data: your name, address, email address, and telephone number. We may also receive this information through one of our business partners. To help us to promote content that is relevant to you, we may add to this data any business profile information that we receive about you from other sources, such as your industry, company size and job title.
Jupiter Island Capital may use the information we obtain, license and collect about and from you for a number of business purposes, including, for example, to: better tailor our website and promotional content to visitor interests; verify your profile information; deliver targeted advertising; inform our partners and Clients of your business-related interests; improve the Platform for internal business purposes; help our advertising partners and Clients better understand the audience they are reaching; and for any purposes we disclose at the time you provide your Personal Data or your consent to our use of the same.
We will only ask for Personal Data that is adequate, relevant and not excessive for these purposes.
Legal basis and purposes of data processing
Whenever we process your Personal Data, we do so for a specific purpose on the basis of a legal justification. Processing of your Personal Data may be justified on one or several of the following bases:
1) Performance of a contract with you
In order to perform the services, you request from us, as set out in the section “Jupiter Island Capital Services”, we use in particular the following data:
- Contact details: your name, telephone number and e-mail address.
- Account data: your Platform account data and other electronic identification data such as IP address and the data you add to your account such as your password, date of birth, gender and other information you share with us.
- Communication data: your requests, any complaints you might have as well as any data you share with us if we communicate with you via e-mail, telephone or social media.
2) Legitimate interest of us or a third party:
Beyond the processing of your Personal Data for the performance of a contract with you, we process your Personal Data to safeguard our or third parties’ legitimate interests provided such interests are not overridden by your fundamental rights or freedoms. Therefore, we process your Personal Data in particular for the following purposes:
- advertising and market- and opinion research purposes, provided you did not object against such use of your data (see section “Updating Personal Data and your Data Subject Rights” below);
- improvement of our products and services including our website;
- prevention and investigation of criminal offences (in particular fraud); and
- defense or enforcement of legal claims.
3) Your consent
As far as you provide us with your explicit, informed consent (e.g. when you have consented to receive marketing e-mails from us and/or third parties we work with for certain products and services) for the processing of Personal Data, such consent presents the legal basis for the processing. You may withdraw your consent at any time by following the steps outlined below in the section “Updating Personal Data and your Data Subject Rights”. Please note that the withdrawal of your consent only has effect for the future and does not affect the lawfulness of processing based on consent before your withdrawal.
4) Compliance with a legal obligation
Any information referred to above under the section “Data Collection” may be used to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
Tracking Technologies and Usage Information
We, Jupiter Island Capital, and our publishing partners, Clients, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer websites, track users’ movements around websites, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. As to information submitted to, through or on our website, we may likewise use service providers to host content, host or implement blogs and forums, or conduct data and marketing analytics with respect to information captured.
Jupiter Island Capital may use a variety of technologies, including “cookies” that automatically or passively collect information from your computer, mobile device or other technology, when you visit Jupiter Island Capital, partner or Client websites. We may also collect information in this way on a third party’s behalf when we serve advertisements and store your Personal Data in log files. Information collected may include your IP address, browser type, operating system, your responses to advertisements delivered by us, date and time, referring URLs and other information normally transmitted in HTTP requests (“Usage Information”).
Usage Information may also be associated with anonymous business profile information about you, such as your industry, company size, and job title. The purpose of this information is to keep the Platform updated and interesting to our users and to tailor content to each individual’s interests. Jupiter Island Capital does not use this information to discern your identity or to disclose your identity to any third party. Jupiter Island Capital stores Personal Data in a separate database from any Usage Information.
We use Local Storage Objects (“LSOs”) such as Flash to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity also use LSOs such as HTML5 and Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To learn how to manage privacy and storage settings for Flash cookies click here:
Advertising / Behavioral Targeting; How to Opt-Out
We may use third-party vendors to enhance the Platform (e.g. for purposes of retargeting). We do not share Personal Data with these third parties, but they may set and access their own cookies, pixel tags and similar technologies on your device and they may otherwise collect or have access to anonymous Usage Information.
When you use the opt-out mechanism, Jupiter Island Capital will no longer use or share any of your Personal Data or anonymous Usage Information, with the exception of Personal Data submitted within the last 30 days to access free content, which the Content Provider may access.
When you opt out of the Platform, we place a cookie on or otherwise identify your browser or device (and/or employ similar technology) to prevent future collection of Usage Information. Opting out of the Platform is not the same as blocking cookies. When you opt out of Jupiter Island Capital’s Platform, we will place a special Jupiter Island Capital cookie on (or otherwise identify) your device or browser in a way that informs our systems not to record information related to your business research activities. If you browse the web from multiple devices or browsers, you will need to opt out from each device or browser to ensure that we prevent personalization tracking on all of them. For the same reason, if you procure a new device, change browsers or delete the Jupiter Island Capital opt-out cookie (or clear all cookies), you will need to perform this opt-out task again.
Please note: This opt-out relies on a cookie and so if you wipe all of your cookies, we will no longer know that you have opted out.
If you would prefer not to accept certain cookies, you may be able to do the following:
- change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; or
- set your browser to automatically not accept any cookies.
However, not all browsers offer these features for all types of cookies and these techniques may not always work.
Please note: As cookies are used for a variety of reasons, not all of which are marketing-related, disabling cookies may adversely impact your online experience.
Sharing of Personal Data
We may share Personal Data and Usage Information with Clients. We may also share with third parties: information other than Personal Data, such as aggregated demographics, user statistics, interest categories and Usage Information with third parties. We may combine your Usage Information with those of other users of the Platform in order to share trend information with third parties. Where we do so, this information will always be in aggregated and anonymous form. We may aggregate Usage Information associated with your Personal Data into business-related research events, which include the form of engagement and content type, topics derived from the content of the event, and date/timestamp of when the event occurred, in anonymous form. An interest event may be, for example, the downloading of a whitepaper on cloud computing, or clicking on an advertisement related to SSL certificates.
In certain situations, we may be required to disclose Personal Data: (a) to protect the legal rights, privacy or safety of Jupiter Island Capital or our employees, agents or contractors; (b) in response to lawful requests from government or by public authorities in any country in which we operate, including for national security or law enforcement requirements; (c) to permit us to pursue available remedies or limit the damages that we may sustain; or (d) as required by law, for example to comply with a subpoena, bankruptcy proceedings, or similar legal process. .
Updating Personal Data and your Data Subject Rights
Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any Personal Data relating to you to the extent required by applicable legal requirements.
You may also request that we verify, correct, or update Personal Data collected through the Platform. We will respond to such request within a reasonable time frame. However, please note that we may delete certain records that contain Personal Data that you have submitted through the Platform in accordance with our routine record keeping. We are under no obligation to store Personal Data indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Data.
We will retain your Personal Data for as long as your account is active or as needed to provide the Platform. You may request that we cancel your account or request that we no longer use your Personal Data to provide the Platform. However, we may retain and use your information to comply with our legal obligations, resolve disputes, and enforce our agreements.
Where your Personal Data is processed in the context of our activities in the European Union, you have the following statutory rights with regards to your Personal Data under the General Data Protection Regulation (“GDPR”):
- you can request access to your Personal Data, including the provision of a copy of the Personal Data subject to processing (right of access according to Art. 15 GDPR);
- you can ask us to update or correct any inadequate, incomplete or inaccurate data (right to rectification according to Art. 16 GDPR);
- you can request erasure of your Personal Data (right to erasure according to Art. 17 GDPR);
- you can restrict the processing of Personal Data (e.g. we may only store but not use your information while we assess your request for erasure – right to restriction according to Art. 18 GDPR);
- where processing is based on our legitimate interests including profiling, you have the right to object to the processing (right to object according to Art. 21 (1) GDPR);
- where we process your Personal Data for direct marketing purposes, you have the right to object to the processing at any time (right to object according to Art. 21 (2) GDPR);
- where processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (right to withdrawal according to Art. 7 (3) GDPR);
- where processing is based on consent or on a contract, you have the right to data portability, meaning that you can ask us to provide your Personal Data in a structured, commonly used and machine-readable format for your use or transfer to another controller (right to data portability according to Art. 20 GDPR);
- you can lodge a complaint with a supervisory authority (right to lodge a complaint according to Art. 15 no. 1 (f) GDPR).
If you wish to exercise any of the rights described above or you have any questions or concerns about how we treat your Personal Data, please contact us at email@example.com. We will respond to your request within one month of receipt, either to provide the information or confirm completion of the act requested or, in certain circumstances, to notify you of an extension of the time frame for response by a maximum of two further months.
Data Security Precautions & Retention
Jupiter Island Capital takes precautions to protect all Personal Data and any other information under its control from misuse, loss or alteration. Jupiter Island Capital’s security measures include industry-standard technology and equipment to help protect your information, and Jupiter Island Capital maintains security measures to allow only the appropriate personnel and contractors access to your information. Unfortunately, no system can ensure complete security, and Jupiter Island Capital disclaims any liability resulting from use of the Platform or from third-party hacking events or intrusions.
Specific retention periods are determined by reference to the type of third-party concerned, as set out below:
- Usage Information is retained for up to 13 months from the date of collection, after which it will be de-identified and aggregated for research and analytics;
- Personal Information from registrations is retained for up to 5 years from the last registration date; and
- cookies expire 18 months after their last update.
Other Web Sites
Jupiter Island Capital does not knowingly collect Personal Data or Usage Information from children under the age of 13 through its website or from any of our affiliates and partners. If you are under 13, please do not give us any Personal Data, and do not provide Personal Data to any website or web service without consulting your parent or guardian. If you have reason to believe that a child under the age of 13 has provided Personal Data to Jupiter Island Capital, please contact us at firstname.lastname@example.org and we will seek to delete such Personal Data from our database.
Consent to Processing and Transfer of Information
The Platform and the servers and facilities that maintain the data we hold are operated in the United States and other countries outside of the European Union. As an international business, our use of information necessarily involves the transmission of Personal Data on an international basis. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be accessed, transferred to and processed in the United States. By using the Platform, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.
If you have any inquiries or complaints about Jupiter Island Capital’s handling of your personal data, or about our privacy practices generally, please contact us at email@example.com. We will respond to your inquiry promptly. If we are unable to satisfactorily resolve any complaint, or if we fail to acknowledge your complaint in a timely fashion, you can submit your complaint online at https://feedback-form.truste.com/watchdog/request, which provides an independent third-party dispute resolution service based in the United States.
Social Media Widgets
Our website includes social media features, such as the “Facebook Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our website (collectively, the “Features” and each a “Feature”). These Features may collect information such as your Internet protocol address, the page you are visiting on our website, and may set a cookie to enable the Feature and related data collection to function properly. Features are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
Our website offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Jupiter Island Capital Services
If you are a customer of a Client and would no longer like to be contacted by the Client that uses our Platform, please contact the Client that you interact with directly. Similarly, should you wish to access Personal Data or to correct, amend, or delete inaccurate data owned by a Client, you should direct your query to the Client.