Privacy Policy

Updated as of: 8/31/2021

 

TDI Administrative Services and its affiliated companies (collectively, “JPI”) are committed to keeping the personal data collected from employees, potential, current and former investors, clients, and other individuals confidential and secure. The proper handling of such personal data is a high priority. Please read this policy carefully to understand how we collect, use, share, and protect your personal data. In this policy, “you” and “your” refers to the individual to whom such personal data relates.

Data We Collect

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional, educational or health information, commercial information and internet activity.

We collect Personal Information through the Site.  When you make a payment through the residential portal, we collect information about your payment history and payment information.  Although we use a Third Party Payment Processor to facilitate any payments made on our Site through the residential portal, we retain this information for accounting purposes and to respond to inquiries, communicate with you about your account, and for other business purposes.  We may collect Personal Information directly from you and automatically through our use of cookies and other data collection technologies on our Sites. We may also collect your Personal Information from third-party sources, such as social media platforms (if you interact with us through your social media account), background check providers, credit bureaus, and third parties to whom you direct us to collect your Personal information.  We will treat Personal Information collected from third-party sources in accordance with this Privacy Policy but we are not responsible or liable for the accuracy of the information provided by third parties or for the third-party policies or practices.

The categories of Personal Information that we collect from you depend on your interactions and engagement with us. For example, we collect:

We intend to implement this Privacy Policy in a manner consistent with applicable employment laws. To the extent that such applicable employment laws are in conflict with this Privacy Policy, we will act in accordance with such applicable employment laws.

Who this Affects

If you are a natural person, this will affect you directly. If you are a corporate investor or client (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal data on individuals connected to you for any reason in relation to your investment with us or our oversight of your account, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Use of Personal Data

The legal basis for our processing of your personal data generally includes one of the following: (a) you have consented to our processing of your personal data; (b) processing is needed to fulfill a request made by you or our contractual obligations; (c) processing is required to comply with a legal or regulatory obligation; or (d) processing is necessary for reasons that are in our legitimate interest as a company, such as to protect our business. For example, we may use personal data:

Sharing of Personal Data

We do not sell your personal data to any third parties for monetary consideration. We may share your personal data as needed to fulfill the purposes described in the “Use of Personal Data” section above, including:

Companies we hire to provide services are not authorized to use your personal data for their own purposes and are obligated to maintain confidentiality of such data. We do not provide your personal data to mailing list vendors or solicitors for any purpose.

In the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets which would generally be transferred is the data we have collected. We will advise a successor or successors in interest of the terms of this policy and our expectation that the successor(s) in interest will comply with the terms hereof.

We may also disclose your personal data to comply with any court order, law, or legal, process, including to respond to any government or regulatory request; to enforce or apply our terms of use and other agreements (including any agreement for the your investment into any of our funds); and if we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or the rights, property, or safety of our customers, or others.

Opt Out Options

Natural persons may opt out of our disclosure of your personal data for the following purposes:

To opt out, please contact us in writing or by email as set out at the end of this policy. Please be specific about which of the above purposes you wish to opt out from, so we can efficiently process your request.

Do Not Track Signals

Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, the Site does not respond to “Do Not Track” signals and consequently, the Site will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.

Employee Access to Data

We have implemented policies and procedures designed to restrict access to nonpublic personal data to those employees with a legitimate business reason to have access to such personal data. These employees are educated on the importance of maintaining the confidentiality and security of this data and are required to abide by our data handling practices.

Protection of Data

We maintain commercially reasonable administrative, physical, and technical security standards designed to protect your personal data, whether written, spoken or electronic. The safety and security of your information also depends on you. Where you have been provided a password for access to our website or your account, you are responsible for keeping this password confidential. We ask you not to share your

password with anybody. We urge you to be careful about giving out sensitive or confidential information through email, as email may not provide a means for complete security and private communications between us and yourself. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us, including to our website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any private settings or security measures we deploy.

Data Retention

We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements.

Children

Our website and services are not directed toward children under 18, and no one under the age of 18 may provide any information to us, including on the website. We do not knowingly collect personal data directly from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us as set forth at the end of this policy and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable legally required or permitted retention standards).

Cross-border Transfers of Personal Data

We are based in the United States, and personal data collected by us and our affiliates worldwide may be transferred to the United States for processing. By using our services or submitting personal data to us or our affiliates, you consent to the transmission of your data outside your own country. We are generally the “data controller” as that term is used under applicable laws.

Your personal data may be processed either locally in the jurisdiction where you work or reside, or in any other jurisdiction where we or our approved third-party service providers operate, worldwide, depending on the needs of the business, to the extent necessary and as permitted by

Your California Privacy Rights

California law entitles California residents to certain additional protections regarding personal data. For purposes of this section alone, “personal data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request:

We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.

You may exercise your right to know and your right to deletion two-times a year free of charge. To exercise your right to know or your right to deletion, contact us at (972) 556-1700 or email us at privacy@jpi.com.

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. We may request additional information about you so that we can match the information you provide to information we already maintain about you. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

Shine the Light: California Civil Code Section 1798.83 gives California residents the rights to request from us once per calendar year certain information regarding our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes. We may share your Personal Information with affiliated third parties for their own direct marketing purposes. You may request information regarding the disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes by contacting us at Privacy@jpi.com.

Revisions to this Policy

We recognize and respect the privacy concerns of individuals. We are committed to safeguarding this data. As a member of the financial services industry, we are providing you this policy for informational purposes and will update and distribute it as required by law. It is also available to you upon request. We may revise this policy from time to time. If we make a material change to this policy, we will post the updated version (with the date of change(s) noted in the policy) on our website and other places we may deem appropriate, and/or notify you by mail or email, so that you are aware of what data we collect, how we use it, and under what circumstances, if any, we disclose it.

Questions about our Privacy Policy

If you have any questions about our privacy policy, please contact us as set forth below, because your privacy and the confidentiality of your data are very important to us.

Email: privacy@jpi.com
Mail: Attn: JPI Privacy Team, 600 E. Las Colinas Blvd Suite 1800, Irving TX 75039
Phone: (972) 556-1700