Introduction

Your privacy is very important to us. This notice (this "Privacy Notice") is provided by Junto Capital Management LP ("Junto", "we" or "us") and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, "processing") and protection of personal data relating to current, prospective and former investors, as applicable, and any other users of our Sites where this notice is posted. The Privacy Notice addresses our privacy practices for such personal data collected online on our websites, mobile applications, and other online services (collectively, “Sites”) as well as through offline means. 

References to "investor" in this Privacy Notice mean any current, prospective, or former investor who is an individual, or any individual connected with an investor who is a legal person, as applicable, and "you" means either an investor or other user of the Sites where this notice is posted.

Who to Contact About This Privacy Notice

This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the "Data Protection Laws"). Junto is considered to be a data controller in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that Junto determines the purposes and the means of the processing of your personal information.

If you have any questions about this Privacy Policy, please feel free to contact Junto at compliance@juntocap.com. 

The Types of Personal Data We Process

The categories of personal data we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches.

We also collect personal data automatically when you use our Sites, including:

Device/Usage Information. We and our third-party vendors, which include analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Sites. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); (i) version of our Sites you are using; and (j) the type of device that you use. We may also track when and how frequently you access or use the Sites, including how you engage with or navigate our Sites. We use this information (including the information collected by our third-party vendors) for analytics (including to determine which portions of the Sites are used most frequently and what our users like/do not like) and as otherwise described in this Policy.

Cookies and Other Electronic Technologies. We and our third-party vendors may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Sites. These technologies, for example, may allow us to tailor the Sites to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about usage of our Sites. We or our third-party vendors also may use certain of these technologies in emails to our investors and users to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. 

Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Sites, because the Sites may not function properly. As we adopt additional technologies, we may also gather additional information through other methods. 

Location Information. When you use the Sites, we may collect general location information (such as general location inferred from an IP address).

How We Collect Personal Data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; and (iii) information we obtain through your interaction with our Sites.

We also may receive your personal data from third parties or other sources, such as our affiliates, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

How We May Use Personal Data

We may process your personal data for the purposes of administering the relationship between you and us, marketing of our products and services, monitoring and analyzing our activities and your Site usage, administering and troubleshooting the Sites, securing and protecting our Sites and business, complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies), and defending our legal rights.

Where permitted by law, we may aggregate and/or de-identify personal data we maintain, and use such data for any purpose, including without limitation for research and marketing purposes, and may disclose such data to other parties such as business partners.

We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal data. Such grounds include, for example, circumstances where:

(i)    processing is necessary to perform our obligations;

(ii)    we are required to comply with a legal or regulatory obligation applicable to us; or

(iii)    we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal data, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal data for such purpose.

What Are The Consequences Of Failing To Provide Personal Data

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in an investor’s subscription in the applicable fund being rejected, compulsorily redeemed or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How We May Disclose Personal Data

We may disclose information about you to our affiliates, service providers, or other third parties to accept your subscription, administer and maintain your account(s), perform our contractual obligations, or for any other business purpose set forth in “How We May Use Personal Data” above. We may also need to disclose your personal data to regulatory, tax or law enforcement authorities comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so.

It may also be necessary, under anti-money laundering and similar laws, to disclose information about an investor to facilitate the establishment of trading relationships.

We may also disclose information about you, or your transactions and experiences with us, to our affiliates or service providers for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.

Retention Periods and Security Measures

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. Personal data will be retained for the duration of an investment in the applicable fund and for a minimum of five years after a redemption or withdrawal, as applicable, of the investment, or liquidation of the applicable fund. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

To protect your personal data from unauthorized access and use, we apply organizational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings.

We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.

Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

For purposes of U.S. federal law, this Privacy Notice applies to current and former investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law.

We may disclose information about our investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process transactions, maintain account(s) or respond to court orders and legal investigations. The types of non-affiliates to which we disclose our investors’ information for our everyday business purposes include financial service providers and non-financial companies (such as data storage providers, analytics providers, and background check providers). We will also release information about you if you direct us to do so.

We may disclose our investors’ information to our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may opt out of this type of sharing by contacting us at 212-409-1900. If you are a new investor, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. If you are no longer our investor, we may continue to disclose your information to our affiliates for such purposes.

You may contact us at any time to exercise your opt-out rights. If you opt out for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.

Additional Information under the Cayman Islands Data Protection Act (As Revised) ("DPA")

The applicable fund may share an investor’s personal information with its services providers. It may also be necessary to share an investor’s information with the Cayman Islands Monetary Authority, the competent authority for purposes of the Beneficial Ownership Transparency Act (As Revised) or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. Any transfer of an investor’s personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPA.

Investors have certain rights under the DPA, including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. 

For residents of the European Economic Area

Junto does not offer its products or services to data subjects in the EEA and accordingly is not required to comply with the General Data Protection Regulation ("GDPR"). Any personal data which we may receive directly from you or third parties will be processed in the United States or other non-EEA jurisdictions and may not receive equivalent legal protections to GDPR.