PRIVACY POLICY

This website is owned and operated by Jones Pipeline Services, LLC and its affiliates (together “JPS”, “us”, “we”, or “our”).

Please read this Privacy Notice carefully as it explains what personal data we process, how we use that personal data, who we share it with, and your rights. It also includes other information regarding our practices regarding the handling of your personal data.

1. What information is covered by this Privacy Notice?

This Privacy Notice governs the processing of personal data that you provide to us, that we collect or receive from you or that we receive about you when you visit our website, attend an event or otherwise interact with us. “Personal data” is any information relating to an identified or identifiable natural person.

2. What information do we collect?

2.a. Information we receive from you

We may collect personal data that you provide to us when you visit our website and/or engage with us to provide you with access to our website and its features. This includes your name, postal and email address, telephone number, employer, job title, department or similar information. Contact data may be provided when you subscribe to receive our newsletter, provide your business card at a meeting or event, when you communicate with us in other ways including applying for a position in which case we may collect candidate data, such as employment history, qualifications, academic qualifications and education records, and any other information that you provide to us when
applying for a role, for example in your curriculum vitae, a covering letter, on an application form or during an interview, or that we have received from a recruitment agency or background check provider.

For example, you may provide us with personal data when you:

· Elect to subscribe to email newsletters;
· Correspond with us via the links available on our website or by email;
· Visit our offices or attend an event we sponsor;
· Apply for a job with JPS; and
· Complete forms on our website.

Registered investors and representatives of investors may access our Investor Portal. SS&C Technologies, Inc. is a third party whose collection and use of your login information and any other personal data collected in relation to your use of the Investor Portal is subject to a separate privacy policy accessible upon registration and login.

Children: Our website is intended to be used by adults and is not directed to children (under 13 years of age or any other age defined under applicable law), and we do not knowingly collect personal data from children. If a child has provided us with personal data, a parent or guardian of that child may contact us by clicking here or by calling us at 1-844.500.2438. We will use reasonable efforts to
delete the child’s information from our databases.

2.b. Information we collect about you

In addition to personal data you provide to us, we may receive information about you that you authorize third parties to provide to us, such as a third party acting on your behalf (e.g. a professional advisor) or from publicly available sources or registers where necessary.

We also may obtain personal data from third-party service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you.

When you visit our website, we may use cookies and other technologies to automatically collect the following information:

Technical information, including your IP address, browser type and version, device identifier, device type, machine ID, computer and connection information, Internet Protocol address (a number that is automatically assigned to your computer or device when you use the Internet), location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
Information about your visit, including the websites you visit before and after our website and products you viewed or searched for;
Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page; and
Similar information for additional content that can be accessed from website pages, such as opening or printing documents or which videos are played and for how long.
To learn more about how we use cookies and how to control which cookies are used, please see our Cookie Policy.

3. How do we use your personal data?

3.a. Website

We use your personal data to diagnose problems with our website or administer our website, to analyse user traffic to measure use of our website and to improve the content of our website and our services as well as to keep our website safe and secure. We also use cookies on our website for the purposes set out in our Cookie Policy.

Legal Basis: We use your personal data in this way as it is necessary for our legitimate interest to: (a) analyse user traffic so that we can improve our website and meet the needs of visitors to our website; (b) to provide you with access to our website; and (c) monitor how our website is used to detect and prevent fraud, other crimes and the misuse of our website. This helps us to ensure that you can safely use our website. Where we use cookies, we rely on your consent to place cookies as required under applicable law – please see our Cookie Policy for further information and how to manage cookies.

3.b. Comply with legal or regulatory requirements and exercise or defend legal claims.

We may need to process personal data to comply with legal and regulatory requirements to which we are subject and/or to defend such claims or exercise our legal rights.

Legal Basis: Processing personal data in this way is necessary to ensure compliance with our legal and regulatory obligations. It is also necessary for our legitimate interests to process personal data for the purposes of exercising and defending such claims.

3.c. To provide you with information about our products and services.

We use your personal data (such as your email address or other contact details) to send you information about our services and other information which may be of interest to you, including events, surveys, updates and other relevant information. We may process your personal data as necessary to better understand your needs and to develop a relationship with you to improve our services; to send you marketing or promotional materials or other information); to respond to your comments or requests for information; and to contact you if needed in the course of processing your requests; to confirm,
update and improve our records; to identify and inform you of services that may be of interest; to offer our products and services to you in a personalized way.

Legal Basis: Where we are permitted to send you such messages under applicable law, our legal basis for processing your personal data is that it is necessary for our legitimate interests to promote our services and provide you with other information which may be of interest to you. We will not send such messages to you if you have opted out of receiving these (please see “What are your rights?” section below for further information).

3.d. For our records, administration, and managing our relationship with you.

We will keep records of your personal data, such as your name, address, account details and marketing preferences, in order to administer our website and keep our records up to date.

Legal Basis: We use your personal data in this way as it is necessary for our legitimate interest to keep records of your personal details and update these when necessary. It is also in our legitimate interests to keep records of any correspondence with you. Our clients are important to us and so we need to keep track of your details and preferences.

3.e. To fulfill our contractual obligations.

The provision of your personal data is necessary when personal data is needed for purposes of entering into or servicing a contract that you, or a company you are associated with, has with us or to receive the products, services or information you or your company request. Refusal to provide your information may make it impossible for us to provide the products, services or information requested or to fulfill our contractual obligations.

3.f. Identifying and evaluating candidates for potential employment.

If you have applied for employment or internship, we will use personal data in the following ways as necessary in our legitimate interests, and to decide whether to enter into a contract with you: to assess your skills, qualifications, and suitability for the role you have applied for; to carry out background and reference checks, where applicable; to communicate with you about the recruitment process; to keep records related to our hiring processes; and to comply with legal or regulatory requirements.

4. Do we use your personal data for direct marketing?

The provision of your personal data for marketing purposes and use of cookies is voluntary. Marketing may be sent by email, posted on our website or other social media, but also sometimes through postal mail or telephone. By providing an email address or other contact information on our website, you agree that we may contact you in the event of a change in this Privacy Notice, to provide you with any Service related notices, or to provide you with information about our events, invitation, or related materials. Please see further information below under “What are your rights” in relation to your rights to opt out of receiving marketing messages. Please see our Cookie Policy for further information on how to manage cookies.

5. With whom do we share your personal data?

Your personal data is intended for JPS but may be shared with third parties in the following circumstances:

5.a. Within JPS.

We may share your personal data among other offices, affiliates and locations within our firm to administer our website, send you information about products and services that may be of interest to you, and conduct the other activities described in this Privacy Notice.

5.b. Our service providers.

We use other companies, agents or contractors to perform services on our behalf or to assist us with the provision of our website, services and products to you. We may share your personal data with the following categories of service provider:

· Infrastructure and IT service providers (including for email archiving);
· Marketing, advertising, analysis, research and communications agencies; and
· External auditors and professional advisers (such as accounts, lawyers or
other consultants).

We will only provide our service providers with personal data which is necessary for them to perform their services to us or assist us with the provision of our website, and we require them not to use your information for any other purpose. We will use reasonable commercial efforts to ensure that all our service providers keep your personal data secure.

5.c. Third parties permitted by law or regulation.

In certain circumstances, we may be required to disclose or share your personal data in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal data to the police, regulators, government agencies or to judicial or administrative authorities).
We may also disclose your personal data to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, safety or property, and/or that of our partners, you or others, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public.

5.d. Third parties connected with business transfers.

We may transfer your personal data to third parties in connection with a reorganization, restructuring, merger, acquisition, or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with this Privacy Notice.

6. What categories of personal data do we disclose for a business purpose?

During the past twelve (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 categories of information collected include information we collect from our members, event attendees, event sponsors, website users and others that interacts with us either online or offline. This does not mean that all examples of that category of information were in fact collected but reflects our good faith belief to the best of our knowledge that some of that information may have been collected about individuals. We will update this disclosure from time to time as appropriate.